IR 05000313/1985023

Insp Repts 50-313/85-23 & 50-368/85-24 on 850901-30. Violation Noted:Failure to Maintain Operating Procedure in up-to-date Status.Deviation Noted:Failure to Implement B&W Safe-End Task Force Recommendation

ML20134B020
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/24/1985
From:	Harrell P, Hunnicutt D, Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20134B011	List: IR 05000313/1985023 ML20134B008 ML20134B012 ML20134B016 ML20134B020
References
50-313-85-23, 50-368-85-24, NUDOCS 8511110180
Preceding documents:	ML20198J032 (27 January 1986)
Download: ML20134B020 (18)

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APPENDIX C

., U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-313/85-23 Licenses: DPR-51'

. 50-368/85-24 NPF-6 Dockets: 50-313

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50-368

Licensee: Arkansas Power and Light Company (AP&L)

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~P. 0. Box.551 Little Rock, Arkansas 72203 l'

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Facility Name: Arkansas Nuclear One (ANO), Units 1 and 2 Inspection At: ANO Site, Russellville, Arkansas Inspection Conducted: September 1-30, 1985 Inspectors:,

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hl of /D 2 88 W. D. Johnson, Senior Resident Date '

Reactor Inspector (pars. 2, 4, 5, 6, 8, 9)

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P. H. Harrell, Resident Reactor

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Dat'e Inspector (pars. 2, 3, 4, 5, 6, 7, 8)

Approved: b /? ) u&& /OlA y/f5

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D. M. Hunnicutt, Acting Chief, Da'te '

Project Section B, Reactor Project Branch L

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- Inspection Summary '

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' Inspection Conducted September 1-30, 1985 (Report 50-313/85-23)

Areas Inspected: Routine, unannounced inspection including operational safety-verification, maintenance, surveillance, design change control, followup on previously identified items, followup on a licensee event report, followup on an allegation regarding an emergency diesel generator Technical' Specification surveillance, and nonlicensed staff trainin The inspection involved 100 inspector-hours (including 6 backshift hours)

onsite by two NRC. inspector Results: Within the eight areas inspected, one deviation was identified (failure to implement B&W recommendations for the high pressure injection / makeup nozzles, paragraph 3).

Inspection Summary Inspection Conducted September 1-30, 1985 (Report 50-368/85-24)

Areas Inspected: Routine, unannounced inspection including operational safety verification, maintenance, surveillance, design change control, followup on previously identified items, followup on an allegation regarding an emergency diesel generator Technical Specification surveillance, and nonlicensed staff trainin The inspection involved 104 inspector-hours (including 5 backshift hours)

onsite by two NRC inspector Results: Within the seven areas inspected, two violations were identified (failure to maintain an operating procedure in an up-to-date status, paragraph 4, and failure to maintain a pipe support in its design configuration, paragraph .4); and one deviation was identified (failure to meet a commitment to B&W Safe-End Task Force Recommendation, paragraph 3.)

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DETAILS

' Persons Contacted

• J. Levine,-ANO General Manager R. Ashcraft, Electrical Maintenance Supervisor

• B. Baker, Operations Manager T. Baker, Technical Analysis Superintendent D. Barton, Maintenance Training Supervisor D.'Bennett, Mechanical Engineer

, R. Blankenship, Nuclear' Engineer .

M. Bolanis, Health Physics-Superintendent

• P. Campbell, Licensing Engineer .

B. Converse, Plant Performance Supervisor E. Corliss, I&C Supervisor D. Crabtree, Mechanical Engineer .

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L2 Dugger, Acting I&C Maintenance Superintendent R. Dyer, Planning and Scheduling Coordinator E. Ewing, Engineering & Technical Support Manager E. Force, Unit 1 Operations Training Supervisor L. Gulick, Unit 2 Operations Superintendent D. Hambien, Quality Control Engineer H. Hollis, Security Coordinator

• L. Humphrey, Administrative Manager R. Jackson, Lead Administrative Trainer D. Johnson, Licensing Engineer G. King, Operations Trainer

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J. Lamb, Safety and Fire Protection Coordinator D. Lomax, Licensing Supervisor A. Massengale, Mechanical Maintenance Supervisor ,

J. McWilliams, Unit 1 Operations Superintendent J. Montgomery, Human Resources Supervisor B. Neal, Lead I&C Trainer

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• M. Pendergrass, Acting Engineering & Technical Support Manager W. Perks, Unit 2 Operations Training Supervisor V. Pettus, Mechanical Maintenance Superintendent

• D. Provencher, Quality Engineering Supervisor E. Rice, Electrical Maintenance Supervisor P. Rogers, Plant Licensing Engineer L. Sanders, Maintenance Manager

• L. -Schempp, Nuclear Quality Control Manager C. Shively, Plant Engineering Superintendent

'R.' Simmons, Planning and Scheduling Supervisor M. Snow, Little Rock Licensing Engineer 4 A.- South, Operations Trainer G. Storey, Safety and Fire Protection Coordinator C. Taylor, Operations Technical Support L. Taylor,--Plant Licensing Engineer

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.i B. T$rwilliger, Dperations Assessment Supervisor

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R. Tucker, Electrical Maintenance Superintendent j y fJ.;Vandergrift, Training Superintendent w

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1J. Waid,' Administrative and. Technical Support Training Supervisor

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' D. Wagner, Health Physics Supervisor

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,, *R., Wewers, . Work Control Center Manager

/ ' J.~ Wilson, Lead Electrical Trainer ( ,

, G. Woolf, Operations . Technical ' Support

'C. Zimmerman, Operations. Technical Support

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• Present at exit intervie _

, The inspectors also contacted other plant personnel, including operators,

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technicians and administrative personne t Followup on Previously Identified Items (Units 1 and 2)

(Closed) Severity Level IV Violation 368/8507-01: , Failure to install a j nonlatching mechanism on fire door (FD) 210 as required by a

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[ design change package (DCP).

l j The licensee has reviewed the requirements for installing a

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nonlatching mechanism on FD 210 for high energy line break (HELB) considerations. The results of this review indicated

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that the room enclosed by FD 210 does not contain high energy i; lines; therefore, HELB considerations for the area are not

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require Even though the licensee failed to install a nonlatching door as required by the DCP, the present latchable fire door has been found to be satisfactor The licensee stated that the failure to install FD 210 in

!1 accordance with the DCP instructions was an' isolated case based j- on confusing information provided in the DCP. The NRC

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inspector reviewed a random sample of other DCPs to verify i correct installation. .No problems were noted during this

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review. The DCPs reviewed by the inspector were installed after the establishment'of the AP&L onsite field construction

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management group. . Based on the review by the NRC inspector, it t

appears that'the installation.of DCPs is now adequate.

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!- >(Closed) . Severity Level V Violation 368/8507-02: Failure to wear beta l goggles in an area requiring beta protection.

.The licensee stated that~this event was discussed with the

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appropriate contractor personnel who agreed to implement a program to ensure that personnel working at sites would follow

{ and abide by plant * procedures.1The -licensee also counseled the:

AP&L individual present during the radiological infraction s

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-5-regarding the necessity for ensuring that contractor personnel obey the requirements in plant procedure In addition, the licensee has agreed to include this incident as an item of discussion in the general employee training and retraining classe (Closed) Open Item 313/8513-02; 368/8513-04: Consistency of training between the operators on each uni The licensee has performed an evaluation to determine if '

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inconsistencies exist in the training between operators on each uni Based on the results of this evaluation, the licensee made changes to the read-and-sign lists of emergency and abnormal procedures provided to licensed operators on both unit This action will ensure that operators on both units '

receive the same level of trainin (Closed) Severity Level IV Violation 368/8513-03: Inadequate emergency and abnormal procedure reviews by licensed operator The licensee has reviewed the required read-and-sign list of emergency and abnormal procedures for completenes Based on this review, the list was revised to include all appropriate procedure To prevent recurrence, the lists for Units 1 and 2 have been removed from the training files and placed under the control of the operator licensing cler Prior to issuance,

, the lists will be reviewed to verify that they are complete, accurate, and up to dat ~

(Closed) Deviation 313/8214-24: Failure to make a procedure change for Unit I warning against the use of the decay heat removal system during accidents involving significant core damag The following two caution notes have been included in the inadequate core cooling section of Unit 1 Emergency Operating Procedure 1201.01:

CAUTION IF SIGNIFICANT CORE DAMAGE HAS OCCURRED, INITIATION OF SUMP RECIRCULATION MAY CAUSE HIGH RADIATION IN AREAS NEAR DECAY HEAT AND HPI SYSTEM COMPONENTS. IF HIGH RADIATION LEVELS ARE EXPECTED, CARE SHOULD BE TAKEN TO EVACUATE PERSONNEL FROM THE AFFECTED AREAS PRIOR TO ESTABLISHING SUMP RECIRCULATIO _ .

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f .3 I- I CAUTION

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FOLLOWING ANY SIGNIFICANT CORE DAMAGE, THE EFFECTS ON ACCESS TO VITAL AREAS DUE TO HIGH RADIATION LEVELS SHOULD BE CONSIDERED PRIOR TO PLACING THE DECAY HEAT SYSTEM IN SERVIC IF:KNOWN LEAKAGE EXISTS ON A SINGLE LOOP (I.E.,

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DECAY HEAT PUMP SEAL LEAKAGE) PREFERENCE IS TO BE GIVEN

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THE OTHER LOOP FOR LONG TERM OPERATION AFTER PRESSURIZER l C00LDOWN IS COMPLET '

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(0 pen) Open' Item 313/8419-03; 368/8419-03: The health physics

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superintendent had not reviewed appropriate lesson plans.

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I_ , The health physics superintendent has completed his review of s

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' health physics lesson plans which are being used by the

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, training staff. However, many operations lesson plans have not i .

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.been reviewed and. signed by the operations superintendent. The

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411censee should ensure.that appropriate lesson plan reviews are

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performed as required by,the cognizant plant superintenden : Procedure 1063.01 states that department heads /section leade'rs and group supervisors /first-line supervisors are responsible

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j for reviewing and approving training sequences and lesson plans

to verify that the needs identified by position task analysis or their own internally generated needs have been satisfie . Licensee Event Report'(LER) Followup (Unit 1)

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' review of records., Unit 1 LER 82-009/01T-0 was reviewed to . determine that

! reportability ~ requirements were fulfilled, immediate- corrective action  ;

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was accomplished,'and corrective action to prevent recurrence has been accomplished.in accordance with Technical Specifications.

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Probleas'with high pressure.injectio'n/ makeup (HPI/MU) nozzles at other Babcock and Wilcox (B&W) plants prompted'AP&L to, inspect and' repair, as

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appropriate, the HPI/MU nozzles on Unit 1.' LER 82-009/01T-0 provided

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~information regarding the inspection and' repair of the Unit 1 HPI/MU x nozzles. The method of inspection and repairs was perfonned based on the recommendations of .the B&W Owner's Group- Safe-End Task Force. AP&L performed the recommended inspections and repairs in accordance with- ,;

. DCP.82-1018. . The NRC inspector reviewed the completed DCP'and noted.no'

probl ems.-

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The Safe-End Task-Force also provided recommendations in Section IS=of

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_their; report,f" Babcock and Wilcox 177 Fuel Assembly Dwner's Group Safe.

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End Task Force Report on Generic Investigation of HPI/MU Nozzle' Component

^. Cracking," B&W document No. ~ 77-1140611-00, to ensure proper,HPI/MU' system ~

- operation. The recommendations - included control of. various. system

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i parameters that.could affect the HPI/MU nozzles,' procedure. changes for-initiating flow through the HPI/MU nozzles during plant startup, and the-

collection'of data for_' evaluation-of'any possible: future: problem < ,

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i-Iniresponse.to a request from the NRC's Office of Nuclear Reactor

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Regulation,' AP&L sent a letter (1CAN048501), date'd April 22, 1985, to the

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-NRC. stating which portions of the task force recommendations would be

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implemented. :The letter _ stated that all recommendations had been l Limplemented except a bypass flow of 1.0 gpm would be maintained in lieu

_ of_the task force recommendation of 1.5 gp '

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. The NRC inspector reviewed the licensee's actions to verify that the I recommen'dations had been implemente During this review, the NRC

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l inspector noted a number of discrepancie These discrepancies are <

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. . The task force recommended that, "A known amount of bypass flow . . . I L should_be maintained and checked frequently ... " The NRC inspector

,. found that there-is notia licensee procedural requirement for the l'

' bypass flow to be checked frequently and that the ficw has not been

checked. -In addition, the NRC inspector also noted that the flowmeter ' for bypass' flow indication has been pegged high.since October 1983, as indicated by a deficiency tag installed on the - flowmeter. The ~

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licensee has failed to meet this recommendation.

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The task _ force recommended that, "In the event'that future anomalies

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are discovered, proper logging of HPI initiations will be . invaluabl ~

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r This procedure should include: nozzles.used. temperature of borated l water storage tank (BWST), temperature of cold leg.before and after l HPI initiation, pressure, flow rate,' and duration of HPI flow." The

[ licensee has not established a formal pro' g ram to institute this

recommendatio Some of the data, such1as BWST temperature, temper-

ature of cold leg before and after HPI, initiation, pressure, and j nozzles used are available from logs.o'r reports that already exist.

The licensee has no procedura1 requirements to record the data for I

HPI flowrate and duration of HPI~ flow. The' licensee has had one i

j event where HPI flow has been' initiated since the issuance of the AP&L letter. 'In this case, the duration of HPI flow was recorded in j

the station log by.the shift supervisor.- The licensee has not fully-F implemented.this recommendation.

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' The licensee has implemented the remaining recommendations made by the l task force. _The NRC inspector verified implementation by review of

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operations logs, procedures, transient reports, inservice inspection

. plan, and nozzle stress analysis.

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The failure of?the licensee to fully implement the task force 1' recommendations,as committed to the NRC in a-letter dated April 22, 1985, *

is-an apparent de'viation. ' (313/8523-01)

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-8- Operational Safety Verification (Units 1 and 2)

The NRC inspectors observed control room operations, reviewed applicable logs, and conducted discussions.with control room operators. The inspec-tors verified the operability of selected emergency systems, reviewed tagout records, verified proper return to service of affected components,

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and ensured that maintenance requests had been initiated for equipment in need of maintenance. The inspectors made spot checks to verify that the physical security plan was being implemented in accordance with the

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station security pla The inspectors verified implementation of radia- i tion protection controls during observation of plant activitie , The NRC, inspectors toured accessible areas of the units to observe plant equipment conditions, including potential fire hazards, fluid leaks, and i

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excessive vibratio The inspectors also observed plant housekeeping and cleanliness conditions during the tour No areas were noted where ,

,. . additional housekeeping attention was required.

I ~The NRC inspectors walked down the accessible portions of the Unit 2 l low pressure safety injection (LPSI) syste The walkdown was performed using Procedure 2104.40 and Drawings M-2232 and M-223 During the walkdown, the NRC inspectors noted minor discrepancies of an editorial

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nature between the drawings, procedure, and plant as-built conditions.

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. Licensee personnel stated the discrepancies would be correcte In addition to the minor discrepancies of an editorial nature discussed above, the NRC inspectors also noted that valves were shown on the piping and instrument drawing (P&ID) but not included on the valve Ifneup. The NRC inspectors reviewed this discrepancy and noted that the planning and scheduling group had issued a plant engineering. action request to onsite

. plant engineering to eliminate the duplicate use of four valve numbers in

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the LPSI system. Engineering assigned the four valves new numbers, and

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, changed and reissued the P&ID on June 27, 1985. However, engineering failed to notify operations of the change in valve numbers due to a

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l poorly defined interface between the two groups. For this reason, the valve alignment sheets contained in Procedure.2104.40 did not accurately reflect the as-built status of the plant. .The failure to maintain a system operating procedure in an up-to-date status is an apparent violation of Technical Specification 6. (368/8524-01)

The NRC inspector also walked down portions of the high pressure safety injection (HPSI) system to verify-that the 'C' HPSI pump, the swing pump, and its associated auxiliary equipment were properly aligned to the 'B'

HPSI pump side. This verification was performed due to the 'B' HPSI pump being out of service. .No problems with the alignment were note During a plant tour on September 10, 1985, the NRC inspector observed two pipe supports in an abnormal configuration. Pipe support 2HCC-32-H16 is on the line between the reactor drain tank and the waste management

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-9-system. P&ID M-2214 indicates that this portion of line 2HCC-32-3 has been upgraded to seismic class I. There was a chain fa attached between pipe support 2HCC-32-H16 and a nearby wall, aph'- .ng an unanalyzed horizontal stress on the pipe support. Thi- ancontrolled change to a seismic class I pipe support is an appareo , violatio (368/8524-02) Upon notification, the licensee removed the chain fal The second discrepancy involved the tailpipe from the 'A' high pressure safety inspection pump discharge relief valve (2HCD-18-1). One pipe support on this line (PS-1 and Figure 295) was disconnected from its anchor bolt This is a seismic class II hanger. Upon notification, the licensee properly installed the pipe suppor These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under Technical Specifications, 10 CFR, and administrative procedure . Monthly Surveillance Observation (Units 1 and 2)

The NRC inspector ob' served the following Technical Specification required surveillance testing:

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. Unit 1 emergency diesel generator monthly test (Procedure 1104.36)

. Unit 2 reactor building spray pump monthly test (Procedure 2104.05)

The NRC inspector verified that testing was performed in accordance with adequate procedures, test instrumentation was calibrated, limiting

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conditions.for operation were met, removal and restoration of the

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affected components were accomplished, test results conformed with'

Technical Specifications and procedure requirements, test results were reviewe'd by personnel other than the individual directing the test, and any' deficiencies identified during the testing were properly reviewed and resolved _by appropriate management personne .

The inspector also witnessed portions of the following test activities: '

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. Unit 2 plant protective system channel 'C' monthly test (Procedure 2304.39) .

. Unit 1 plant protective system channel 'C' monthly test (Procedure 1304.39)

. Unit 2 emergency diesel generator 1 monthly test (Procedure 2104.36)

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. Unit 2 emergency diesel generator 2 monthly test (Procedure 2104.36)

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( No violations or deviations were identified.

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, ' Monthly Maintenance Observation (Units 1 and 2)

I Station maintenance at.tivities'.of safety-related systems'and components listed below were observed to ascertain that they were conducted in

, accordance with approved procedures, Regulatory Guides, and industry codes or standards; and in conformance with Technical Specifications.

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The following items were considered during this review: the limiting j' conditions for operation were met while components or systems were

removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures ~and were inspected as applicable; functional testing and/or calibrations were

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performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by

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qualified personnel; parts and materials used were properly certified;

radiological controls were implemented; and fire prevention controls were

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LJob orders (J0) were reviewed to determine status of~ outstanding jobs and to ensure that priority is assigned to safety-related equipment maintenance which may affect system performanc i

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The following maintenance activities were observed:

i Repair of discharge check valve on Unit 1 service water pump

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5InvestigatecauseofUnit2plantprotectionsystemtripannunciatori

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i cui GO 791 A15)

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Disassemble and repair Unit 2 high pressure safety injection pump-(JO'701354)

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Repair or replace operator for Unit 2' service water valve 2CV-1419-1

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_ ;Desian Chanae' Control (Units 1 and 2) '

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This inspection is:a continuation of an' inspection initiated during the

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[' last inspection period.- During this portion of the inspection, the NRC j inspector reviewed DCPs that were completed during the recent refueling outages on Units 1 and The DCPs reviewed have not had a final review

.; performed by the onsite plant engineering group. These DCPs, although.

!' not processed.through the complete review cycle, were reviewed to determine

~the. status of the current-design. change program at~AN >

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11-This review included verification that design changes were made in accordance with Technical Specifications, industry guides and standards, 10 CFR, and plant procedure The DCPs listed below were reviewed by the NRC inspector:

Unit 1 83-1052 Install new actuators on valves CV-1054, CV-2215, and CV-2221 83-1063 Upper core barrel bolts replacement 84-1019 Installation of. local manual circuit breakers on emergency diesel generators 84-1040 Vital power for control room communications radio Unit 2

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82-2019 Installation of service water loop high point vents 83-2029A Pressurizer relief line pipe support modifications

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83-2152 Installation of new emergency feedwate'r flow transmitters 84-2044 Duct modifications to cool panel'2C384 c85-2007

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Installation of local switches for emergency diesel generator room exhaust fans The DCPs listed above were-reviewed for the following, as appropriate:

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. Review and approval was in accordance with the requirements of 10 CFR Part 50.59 and the reviews'were technically adequat . Review and approval was in accordance with Technical Specification, quality assurance (QA), and quality control (QC) requirement . Postmodification test records were reviewed by the licensee and an evaluation of the test results was performe . Acceptance criteria was provided and' test results met the established criteri . Test deviations were resolved and retesting performed, if required.

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. Appropriate changes were made to operating and surveillance procedures.

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. : Drawings were revised to reflect the DCP change l J

. Field change notices (FCNs) received the proper reviews and

approvals.

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. E QA ~and/or QC reviews of. the completed DCPs had been perf.:nne .

During the review, the NRC inspector noted that FCNs- had been reviewed by

, ' the ' plant safety committee (PSC) and the general manager (GM), but had not been reviewed by QC. Under the present program, the onsite plant l engineering superintendent determines during his review of an FCN, whether or not the FCN will receive QC, PSC, and/or GM review. Typically,

the FCN will" receive a review by QC, PSC, and/or the GM if the FCN changes the function,. safety, or reliability of the original-design j, change package. The choice of which individual's review the FCN is

!- dependent on the' decision made by the onsite plant engineering superin-

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e tendent~. 'In a discussion _with the onsite plant engineering superintendent

.. and,in a subsequent separate discussion with the QC manager, the NRC

.. inspector noted a difference of philosophy between the two as to which

! .FCNs should receive a QC review. . Based on questions raised by the NRC

} inspector,-the two individuals' met and~ agreed as_to what FCNs the onsite

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plant-engineering superintendent would forward for QC review. This j'e previously undefined interface ~between plant engineering and QC will

, 'res'ltu in a procedure change that will include a requirement that all j .FCNs routed to the PSC for review will also receive a QC review. The

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j ; procedure revision has.not yet been-issue The NRC inspector will.'

review this item after the procedure receives final approval to' verify

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appropriate FCN '

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L The: problem discussed above regarding the interface between-plant engineering and QC'is the second example of a plant. engineering interface

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., problem noted during this insp'ection period. -The first example,

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5 ' discussed in paragraph 4 of this report,'resulted in a violatio The-

~ licensee should review the interface between plant engineeririg and other

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onsite groups-to ensure that the'necessary information is being provided

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by plant engineerin '

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No violations or deviations were identified.'

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. 8.' Followup on Allegation Number 4-85-A-087- (Units 1 and 2),

~ An' allegation was made that the timing of emergency' diess.1 generator

'(EDG) starts on the Unit'l EDGs was not being performed in accordanc {; with the requirements stated in the-Technical Specification The Unit 1

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i Technical Specifications' require that the EDGs be' started and ready-for i- loading within 15 seconds. The. alleger stated that the point when the

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timing of<the start was initiated was not correct in that the operators

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-13-were not initiating the timing when the start button was depresse In the case of starts locally in the EDG rooms, the operators were initiating timing when they heard air enter the starting motor In the case of starts in the control room, the operators were initiating timing when the EDG run indicating light was illuminate The NRC inspectors reviewed the allegation by discussion with operations personnel, observation of EDG starts, and a review of the records of past start A review of past Technical Specification surveillance records did not provide any definite conclusions regarding any one shift consistently recording low start times. -The data indicated that start times varied from 10.5 to 14.5 seconds. The NRC inspectors also reviewed past results of integrated emergency safeguards features (ESF) tests. When ESF tests are performed, a chart tracing of the time period from-the receipt of an EDG start signal to the closing of the EDG output breaker is recorde The results of the chart tracings indicate that the length of time from start signal initiation to breaker closing ir approximately 6 to 7 second The alleger also contacted licensee management personnel with the i

concerns regarding performance of EDG start surveillances. The licensee performed a review and reached the conclusion that timing of starts between the Unit I crews was not consistent. The licensee found that two crews started timing from the control room when the EDG run light illuminated and stopped the timing when the voltage had cycled twice through 4160 volts. The remaining four crews started timing when the start switch was actuated and stopped timing when the voltage reached 4160 volts. For starts from toe EDG rooms, one crew timed from when air entered the starting motors until the voltage cycled twice through 4160 volt The remaining five crews timed from pushing the start button

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'until the voltage reached 4160 volts. To eliminate the inconsistency between the crews, the licensee changed the surveillance procedure to specify precisely the initiating and ending events for timing EDG start The licensee also concluded that the methods used by all the Unit 1 operations crews were conservative when compared to the Technica Specification-requirements.

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, Based on the reviews and observations by the NRC inspectors and a review

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-of the licensee's analysis, it appears that the licensee's timing of -

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diesel' generator starts have been technically adequate. Even though the-Etiming of the starts were not consistent between shifts, the method used

adequately met the Technical Specification requirements. The revision o .the operating procedure should eliminate. confusion between operating

_, - crews and provide a consistent method of performanc ,

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'The NRC' inspectors also verified that the timing of EDG starts by the Unit 2 operating crews were being performed satisfactorily. No problems

were noted during observations of the Unit 2 EDG start No violations or deviations were note . Non-Licensed Staff Training (Units 1 and 2)

The objective of this inspection was to evaluate the effectiveness of the training programs for the nonlicensed plant staff. Training programs

, for the following groups of personnel were included in this review: ,

. Principal staff members

. Maintenance technicians

. Health physics and chemistry technicians

. Nonlicensed operators'

. Technical staff members

. Quality control inspectors General

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l The licensee's site training staff includes 54 personne These are listed below by title:

. Training Superintendent

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. Maintenance Training Supervisor Instrumentation and Controls Trainers (4)

Mechanical Maintenance Trainers (3)

Electrical Maintenance Trainers (4)

. Unit 1 Operations Training Supervisor

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Lead Classroom Trainer

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Lead Simulator Trainer

' Operations Trainers (10)

. Unit 2 Operations Training Supervisor Lead Classroom Trainer Lead Simulator Trainer (vacant)-

Operations Trainers (9 + 1 vacant)

. Simulator Support Supervisor

, _ Simulator Engineers (3)

Softwear Specialists (2)-

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. Administrative and Technical Support Training Supervisor

- General Employee' Trainers (4) R Health Physics and Radioactive Waste Trainers (2)

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Chemistry / Radiochemistry. Trainers (2)

- Lead Administrative Trainer i Graphics Specialist

In addition, the following personnel support the training staff:

' Full-time clerks (5) .

Contract clerks (4) l

. Temporary draftsman Consultants (2)

10ffice Services Personnel . (Training Library)

i AP&L Energy Supply Skills Center personnel provide basic entry level training.in power plant principles and maintenance skills for

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employees needing'.this type of trainin These courses are conducted,'in'part, at the ANO training facility and, in part, at-

} - the Energy Supply Skills Center.

, Event Evaluation

,- The NRC inspector reviewed several recent equipment failures and  ;

operating events to' evaluate the following items:

. Whether classroom training or on-the-job-training prior to the event was sufficient to have either prevented or mitigated the even I

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.- The qualifications of the personnel involved.

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.. Whether responsibility'for. administering ard evaluating the

! related training was clearly. established.

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. Whether any lessons' learned from the event were factored into the training' progra Classroom training forJnonlicen ed' personnel involved in the events reviewed (primarily maintenance and. operations department personnel)

However .in most cases,' classroom .

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has been quite extensiv training was'too general in:natureEto have:significant potential to

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. prevent or mitigate the events re' iewe ~

v For example, a classroom *

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course on centrifugal pump maintenance is given' to mechanica' l

- maintenance personnel. ' This. course does not' include the specific ~

' details of properly setting the balance drum clearance on the-Unit 1 steam-driven emergency.feedwater pump. ; Laboratory training is i provided in which personnel actually perform disassembly and repair

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[ of..various types of pumps, but this'does not include every specific

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pump.in use~at the, sit This classroom and laboratory training is

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intended to provide the craftsman with the basic knowledge and skills necessary to perform his/her assigned tasks. . It does not

! attempt to; nor could it, provide all the knowledge and skills

necessary to' repair each specific component in the plan Even well p  ; trained and experienced personnel.need the guidance of a

' well-written procedure in order to properly perform complex

,i , maintenance task For several of the events reviewed, the licensee i ,had revised and improved the related procedure following the even The licensee' has. recently revised the program for on-the-job training. The new program is quite comprehensive and it should lead

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to overall improved qualifications of plant personne For the events reviewed, the NRC inspector did not find that on-the-job

{ training was a facto Experienc'ed and qualified personnel were j involved,-but the guidance and-caution statements in the procedure were insufficient in some case A review of the licensee's administrative procedures for station

! training indicated that. responsibility for administering and

' evaluating training is clearly assigned.

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The NRC inspector found that lessons learned from the events had been factored into the training program when_ appropriate. The t' ~ -- primary means of accomplishing this is by use of the Training .

Evaluation-Action Request (TEAR).

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The TEAR is initiated by a planti

,7 staff member to identify needed changes in lesson plans or a nesd'

for new training courses. The training superintendent assigns a

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training-staff member to respond to'the request,by developing'a new ,

course, modifying a lesson plan, or by other'means. Feedback on action taken'is provided to the originator. The TEARS are logged ~ '

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and tracked to completion by training department personne " "

- Interviews with Personnel .

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, .-Several plant personnel were interviewed by the NRC inspector to '

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determine whether.-their general knowledge in administrative

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~ controls, radiological safety, industrial safety,' security, the ^

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emergency-plan, and quality assurance'was sufficient for their

! . . assigned tasks. Interviews were conducted with new,' experienced, F a

'nd temporary personnel.- The general knowledge of these employees.

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in the stated areas was adequat ,

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The general employee training program covers these topics plus plant, i

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organization and plant description _in a 40-hour course given to new 4

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employees. Refresher training is given to -regularly employed personnel each calendar yea ;

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Interviews were conducted with maintenance and nonlicenqed '%

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. operators to determine rhether they had received training for ,

specific-tasks' assigned, such as complicated surveillance-tests, major. equipment repair, operating procedures, and emergency procedures. Training for complicated surveillance tasks and major equipment repairs is most.often accomplished with on-the-job training. Some items, such as rsactor coolant pump seal.,

replacement, are-covered by specific training courses. In some cases, equipment vendors are contracted to provide specific training

on maintenance of their equipment. Classroom and on-the-job

- training on operating and emergency procedures was provided for

. nonlicensed operators.-

E Record Review -a ;

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- Training records covering the [eriod of Januarf 1,1984, through- ,

September 1,1985, were reviewed for 17 plant staff personnel. The *

-NRC inspector found that the training provided met or' exceeded, ~

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- regulatory requirements and licensee connitments. .In reviewing the

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- records of shift technical advisor. (STA)~ training, tha NRC inspector

found that examinations have tete given following-the annual ,_

. requalification training, but no minimum acceptable score has been

,~' established and no remedial training'has been required ~ for an STA

< receiving a low score on the test. Licensee training staff personnel were aware of this weakness in their program, and stated

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that this will be corrected in the new STA training program which is s under developmen .

r E e.- Training Program Accreditation Status

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The NRC inspector reviewed the status of the licensee's efforts to gain accreditation of its training programs by the Institute of Nuclear Power Operations (INP0).- The training programs and their>

status are listed belo .

. Nonlicensed operator, licensed operator, licensed senior-operator, and licensed operator!reggjification: Accreditation

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was awarded in January 198 '. Shift; technical' advisor: -Theself-e'valuationreport(SER)'is scheduled to be submitted in' June 198 . Instrumentation and controls technicians, electrical maintenance personnel, and mechanical maintenance personnel:

The SERs were submitted to'INP0 in June 1985. The INP0 accreditation-team visited the site in August 198 . Health physics technicians and chemistry technicians: -The SERs '

are scheduled to be submitted to :INP0_-in January =198 .

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-Onsite technical staff and' managers:' -The SER is scheduled to

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be submitted to INP011n' June 198 g_

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. Conclusions

, The licensee has made a large commitment to training, as evidenced by the large staff and the modern and spacious training facilitie '

The NRC inspector did not find indications that.1,nadequate classroom or on-the-job training was a factor in the events reviewed. Methods have been established to update the training program in response to

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lessons learned from abnormal events, procedure changes, design changes, and regulatory changes. Personnel-interviews indicated general satisfaction with the current training program, and the experienced personnel interviewed noted training program improve-

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ments over the past 2 years. Several of the laboratory courses were mentioned as being particularly beneficial. No significant discre-

! pancies were, identified during the records review portion of this inspection. The licensee is aggressively pursuing a realistic

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schedule.to obtain INPO accreditation of its various training program '

No violations or deviations were identifie . Exit Interview

~ The NRC inspectors met'with Mr. J. M. Levine (ANO General Manager) and

' other members of the AP&L staff at the end of this inspection. At this

' meeting, the inspectors tummarized the scope of the inspection and the finding t

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