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ARKANSAS POWER & LIGHT CCMPANYPCST CFFICE BCX 551 UTTLE ROCK. ARKANSAS 72203 (501) 371-4000

November 21, 1980

1-110-242-110-32

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Mr. K. V. Seyfrit, DirectorOffice of Inspection & EnforcementU. S. Nuclear Regulatory CommissionRegion IV611 Ryan Plaza Drive, Suite 1000Arlington, Texas 76011

Subject: Arkansas Nuclear One - Units 1 & 2Docket Nos. 50-313 and 50-368License Nos. DPR-51 and NPF-6Response to Inspection Reports50-313/80-17 and 50-368/80-17(File: 0232, 2-0232)

Gentlemen:

In response to the Items of Noncompliance included in the subject report,the following is provided.

NOTICE OF VIOLATION

Based on the results of an NRC inspection conducted during the period ofAugust 22 - September 21, 1980, it appears that certain of your activitieswere not conducted in full compliance with NRC regulations and the condi-tions of your license (NPF-6), as indicated below:

Technical Specification 3.6.2.3 states, "Two independentcontainment cooling groups shall be OPERABLE with twocooling units in one group and at least one cooling unitin the second group." This Limiting Condition for Oper-ation is applicable in Modes 1, 2 3 and 4

Action statement b. of Technical Specification 3.6.2.3requires that "With two groups of the above requiredcontainment cooling units inoperable and both contain-ment spray systems OPERABLE, restore at least one groupof cooling units to OPERABLE status within 72 hours orbe in at least HOT STANDBY within the next 6 hours andin COLD SHUTDOWN within the following 30 hours. Restoreboth above required groups of cooling units to OPERABLEstatus within 7 days of initial loss or be in at leastHOT STANDBY within the next 6 hours and in COLD SHUTDOWNwithin the following 30 hours"

8 0 3 2' 2 4 00 M MEMBEA MCCLE SOUTH UT1UTIES SYSTEM

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Mr. K. V. Seyfr M -2- November 21e 1980, ,

i Contrary to the above, the licensee operated Unit 2 inthree of the four applicable Modes for reactor operations(Modes 1, 2 and 3) from August 20, 1980 through Septem-

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ber 3, 1980, with two groups of the containment coolingunits inoperable. This resulted in exceeding all of thepermissable elapsed time limits specified in TechnicalSpecification 3.6.2.3.

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This is an infraction (368/80-17-01).RESPONSE:

A review of the failure of the administrative controls which allowedoperation in an out-of-spec, condition for 14 days was initiated bythe plant staff on the afternoon of 9/3/80. A special inspection ofthis incident was performed by members of the offsite nuclear reviewgroup. The failures occurred both on the part of the shift supervisoranalyzing the test and the Assistant Operations Superintendent per-forming the second, independent data review.

The cause of the failures of both individuals who were involved appearto be very similar in nature:

1) Being " pre-conditioned" to expect the "No" in surveillance proce-dure step 3.3.1 to be circled because of the blank flange instal-lation on 2VCC-2A S.W. coils.

2) Inattentiveness to detail during review ;aused by haste.1 In both individual's cases, only the surveillance test section 3.0 " Test

Acceptance Criteria" was reviewed in detail; the preceding two pages(steps utilized to perform the test) were reviewed for completeness only(i.e., all slots filled in and initialled) which resulted in no reviewon their part of the actual flow rate data.

A review of all other surveillances in the Unit 2 Assistant OperationsSuperintendent's files (approximately 80 separate tests) indicated no

| other out-of-spec. data.

The individuals involved have been thoroughly counselled. Specific coun-selling included the necessity for increased alertness, attentativenessi

to detail, and necessity for temporary procedure criteria changes versusi

| case-by-case evaluations of out-of-tolerance conditions.

Procedure formats have been reviewed to ensure all required data andcriteria are readily and easily discernable.

Measures to reduce the time demands on the Shift Supervisors have beentaken by the addition of the Shift Administrative Assistant to the plant:

staff. These individuals will provide reduction in the Shift Supervisor's! administrative work load and will add another check of surveillance para-

meters.

| Corrective action has been completed. The Shift Administrative Assistants! (SAA) have been hired and are in a training program. The SAA's are sche-j duled to start performing duties on shift on January 1, 1981.

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Mr. K. V. Seyfrit -3- November 21, 1980. ,

NOTICE OF VIOLATION

Appendix B of the Technical Specifications, Section 2.2.3.a., requires thata series of calculations be performed to determine the maximum time for eachcontainment building purge duration. On September 4, 1980, calculationsestablished a maximum purge time of 10 minutes 44 seconds as recorded onPermit GR 80-46.

Contrary to the above requirements, the containment building was purged onSeptember 4, 1980, without knowledge of the start time of the purge. Thepurge time probably exceeded 10 minutes and 44 seconds and an additionalamount of purge time would have occurred, except that the Senior ResidentInspector called the lack of purge time monitoring to the attention ofoperating personnel.

This is an infraction (368/80-17-02).

RESPONSE:

This incident was promptly investigated by the plant staff. In addition,members of tne offsite nuclear review group performed a special inspectionof this incident.

The predominant administrative / personal errors were determined to be:

1) Not exercising sound operating judgement to immediately terminate thepurge alignment on fan failure.

2) Lack of appreciation for the timing precision required during inter-mittant purge steps to preclude exceeding offsite dose limits.

3) Lack of adequate communication and coordination on shift.

4) The involvement of the Shift Supervisor in specific operations func-tions (acting as an operator) to the point of losing overview capa-bility.

5) Lack of adequate notification from the I&C Department personnel tothe control room of removing required equipment from service.

6) Less human factor consideration used ia formatting release procedurethan desirable.

7) Distracting effect and loss of concentration due to close scrutinyof operators by NRC inspectors.

Corrective actions to reduce the likelihood of recurrence are:

1) The operator having the most significant contribution to this event(the Shift Supervisor) has been thoroughly counselled regarding thefollowing items:

a. His responsibility to maintain a proper over-view for propercoordination and control of all operations and not to becometotally involved with any specific operation.

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Mr. K. V. Seyfrit -4- November 21, 1980. ,

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b. His responsibility to assure that important routine tasks con-tinue to receive full concentration of the operators and him-self. .

c. The vital importance of maintaining precise timing of purgingoperations and the results of exceeding purge times.

2) Additionally, the entire operating staff has been apprised of thisevent, and the necessity for close cooperaticn and awareness, atten-tiveness to detail and methods to minimize personal susceptibilityto intimidating effects of close NRC scrutiny. The purge releaseprocedure has been reviewed and is being revised to provide a bettermethod of formating, proper depth and adequacy of cautioning state-ments.

3) Specific counseling with instrument technicians who were involvedwith the isolated stack flow transmitter has been performed. Train-ing with all the I&C technicians reviewing this event, the effectsof isolating equipment without proper clearance, and the necessityto follow proper procedures when performing maintenance has beenconducted. Corrective action will be completed by December 1, 1980when the revised purge release procedure will be issued.

NOTICE OF DEFICIENCY

Technical Specification 6.9.1.9 requires, in part, that a completed copyof a licensee event report form be submitted by the licensee to the Nu-clear Regulatory Commission within thirty days of the occurrence of anyevent that results in ". . . conditions leading to operation in a degradedmode permitted by a limiting condition for operation or plar.t shutdownrequired by a limiting condition for operation".

Technical Specification 3.7.1.2 requires that two emergency feedwaterpumps be operable, with one of the pumps being a turbine driven pump(2P7A) powered from the steam supply system while in Mode 1 operation.

Contrary to the above, the turbine driven emergency feed pump (2P7A) wasdiscovered to be inoperable while testing it in Mode 1 operation onJuly 23, 1980, and licensee failed to submit a licensee event report (LER)form reporting this failure to the Nuclear Regulatory Commission.

This is a deficiency (368/80-17-03).

RESPONSE:

The failure of the turbine driven emergency feedwater pump (2P7A) whichoccurred on July 23, 1980, was the result of incorrect installation oftest equipment during testing to determine reliability of the subjectequipment. Since the failure (an overspeed trip) occurred during thetest, was corrected prior to completion of the test, and was not a validfailure, the ANO staff determined the event to be non-reportable. Thisdetermination was a conscious decision after discussion of this incidentby the AN0 Plant Safety Commission (PSC) and the ANO General Manager andwas based upon AN0's interpretation of Regulatory Guide 1.16.

Although we believe that the reportability of this event is subject tointerpretation, AP&L will submit an updated licensee event report todocument this failure. This deficiency has been reviewed by the PSC.

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Mr. K. V. S:yfrit -5- November 21, 1980. .

Corrective action will be completed by December 1, 1980, when a licenseeevent report will be submitted to document this failure.

ACTIONSTOIMPROVEOVERALLCONTROLOFLICENfdDACTIVITIES

Your letter also asked us to described the actions we have taken or planto take to correct the broad deficiencies in implementation of AP&L'sQuality Assurance Program.

Quality assurance requirements have been established for the design andconstruction of AP&L nuclear plants to assure that regulatory require-ments and licensino commitments, codes and standards are correctly trans-lated into the as-built plant. It is the objective of this program toestablish quality assurance requirements to ensure that activities suchas operating, testing, refueling, repairing, maintaining and modifyingthe plant are conducted in accordance with good engineering practices.To meet this objective, a Quality Assurance Program for Operation Appli-cable to AP&L Nuclear Plants has been established by Arkansas Power &Light Company. The Program, identified as Quality Assurance for Opera-tions, provides criteria to be applied to the operational phase of theplant. The program controls those phases, as applicable, for the design,procurement, manufacturing and fabrication, installation, reoair, main-tenance or changes made to existing plant structures, components andsystems that prevent or mitigate the consequences of a postulated acci-dent which may cause undue risk to the health and safety of the public.It assures that the necessary operational safeguards are applied inaccordance with the criteria for safe, efficient and reliable operation.The program is an outgrowth of the principle that quality assurance ema-nates from each individual contributor, and that management is responsi-ble for creating an awareness of quality.

A review of the Quality Assurance Program was recent:y completed by anoutside, independent consulting firm. Based on the recommendaticns ofthis review, the QA Section has reorganized and has authorization toincrease its staff by four (4) people for the nuclear program. Two (2)of these individuals will be located at ANO. In addition, we are in theprocess of revising the QA Administrative Procedures (QAA's) and theQuality Assurance Procedures (QAP's/AN0's) to provide more definitiveprocedures for implementation of the AP&L Quality Assurance Program. TheQA Section has expanded its audit program to include those audits previ-ously performed by the Corporate Safety Review Committee and to conductmore surveillance of in process activities at ANO. These specificationswill provide significant improvement in assuring implementation of the,

AP&L Quality Assurance Program.

AP&L has implemented a number of organizational changes which we feel willimprove our overall operation. We have restructured our corporate organi-zation to create a separate Nuclear Operations Department within Generationand Construction. Previously, Nuclear Operations was a section within theGeneration Operations Department. The new Nuclear Operations Departmenthas a Nuclear Services Section which will provide dedicated support to AN0

) and will function to coordinate the corporate office support for ANO. Inaddition, the corporate Plant Maintenance and Availability EngineeringSection has been directed to make AN0 its top priority and is now workingon programs directed at improving the quality and effectiveness of the ANOmanagement system and operation.

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Mr. K. V. Seyfrit -6- November 21, 1980, ,

The ANO organization has also been modified to ensure improved managementcontrols. The Operations and Maintenance Department has been separatedinto an Operations Department and a Maintenance Department. This changewas required to ensure more detailed management control over these two keyareas of nuclear plant operation. We have also created a Special ProjectsGroup reporting to the General Manager. This group will be responsible forresolution and implementation of ongoing projects as determined by the Gen-eral Manager which will relieve this workload from the line managers andpermit them to better control their areas of responsibility. The Managerof Special Projects will be the chairman of the onsite Plant Safety Com-mittee. We have also created an Operations Assessment Group on the ANOstaff which will provide a detailed review of plant operations and reviewthe operating experience of other nuclear units. We have just recentlyincreased and reorganized the staffs of the QA and QC groups based on anevaluation by an outside consultant. These changes will permit these groupsto provide more and improved audits and inspections of our licensed activ-ities. Management will continue to take action to resolve the problemsidentified by the Quality Program.

We have significantly increased the level of management involvement andreview of our nuclear activities. The Vice President, Generation andConstruction and Director, Nuclear Operations have been onsite for oneor two days almost every week since mid-September of 1980 and have beendeeply involved in specific areas of licensed activities, including:Training, Health Physics, Operations, and Maintenance. We expect tocontinue this level of involvement as necessary to ensure adequate atten-tion and control. We have conducted detailed monthly briefings to theAP&L Chief Executive Officer and his key executive staff members of theongoing activities at ANO. To date, two of these briefings have beenconducted at ANO. We are also providing periodic reports to the AP&LBoard of Directors to ensure they are aware of activities impacting thesafety and operation of ANO.

AP&L has initiated a number of specific programs intended to improve theoverall management and control of ANO. Our August 13, 1980 letter toMr. Seyfrit, described the Position Task Analysis (PTA) program which will,

certainly result in better definition of position responsibilities and moreappropriate training programs. A Task Management System is also underwaywhich is performing a detailed review of each of the functional areas atANO. The purpose of this review is to evaluate the activities of eachgroup, ensure adequate systems are available to permit the efficient util-ization of existing manpower and to evaluate the need for additional man-power. AP&L is also in the process of implementing a new relational database management information system. This system, when complete, will pro-vide a powerful tool to assist AP&L management in the control of our nu-clear activities. The new computer for this system will be on site beforethe end of this year and operational by May 31, 1981.

We have brought in outside, independent consultants to review certain areasof our operation and identify our weak and problem areas. Areas that have

, received this review include Health Physics, Training, Quality Assurance' and Quality Control. Specific action programs have been initiated as a

result of each of these reviews.

We have increased our audits and inspections of the AN0 Security Systemand have authorized additional I&C tecMicians who will be dedicated to

! supporting the Security System. Until we can fill our authorized I&C

. Mr. K. V. Seyfrit -7- November 21, 1980,

positions, we have obtained the services of a vendor to provide I&C tech-nicians to provide the necessary support.

We have also increased the use of special audits by the Corporate SafetyReview Committee to provide detailed investigation of deficient areas ofANO operation.

We are in the process of implementing an entire new set of AdministrativeProcedures at ANO. These new procedures are written to reflect the recentrevision to the AP&L Quality Assurance program. These procedures providesignificant improvement in the quantity and quality of direction providedto the ANO staff on the conduct of business at ANO.

AP&L is deeply committed to the safe, efficient operation of its nuclearunits. In order to ensure this, we are dedicated to providing the toolsand resources necessary to adequately manage and control our activities.I believe that previously identified programs are a positive step in thatdirection and that the level of management attention focused on ANO willensure a continuing program of identification and correction of weaknessand problem areas.

We certainly hope that this letter provides a clear and complete overviewof the actions we have taken and are continuing to take to upgrade thelevel and quality of our management controls of licensed activities atANO. If you have any additional questions or concerns, we would be morethan willing to discuss them with you.

Very truly yours,

OM0David C. TrimbleManager, Licensing

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cc: Mr. Victor Stello, Jr., DirectorOffice of Inspection and EnforcementU. S. Nuclear Regulatory CommissionWashington, D. C. 20555

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