ML103160350
| ML103160350 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/12/2010 |
| From: | Clark J NRC/RGN-IV/DRP/RPB-E |
| To: | Berryman B Entergy Operations |
| References | |
| IR-10-004 | |
| Download: ML103160350 (72) | |
See also: IR 05000313/2010004
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
R E GI ON I V
612 EAST LAMAR BLVD, SUITE 400
ARLINGTON, TEXAS 76011-4125
November 12, 2010
EA 10-233
Brad Berryman, Acting Vice President, Operations
Entergy Operations, Inc.
Arkansas Nuclear One
1448 S.R. 333
Russellville, AR 72802
Subject: ARKANSAS NUCLEAR ONE - NRC INTEGRATED INSPECTION
REPORT 05000313/2010004 AND 05000368/2010004
Dear Mr. Berryman:
On September 30, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Arkansas Nuclear One facility. The enclosed integrated inspection report
documents the inspection findings, which were discussed on September 27, 2010, with you and
members of your staff.
The inspections examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
One violation is cited in the enclosed Notice of Violation and the circumstances surrounding it
are described in detail in the subject inspection report. The violation involved the failure to
implement appropriate foreign material exclusion controls in areas designated as Zone 1 foreign
material exclusion areas as required by station procedure (EA-10-233). Although determined to
be of very low safety significance (Green), this violation is being cited in the Notice because
Arkansas Nuclear One failed to restore compliance within a reasonable time after the violations
were identified in NRC Inspection Reports 05000313, 05000368/2008005, 2009004, and
2010003, as specified in Section 2.3.2.a of the NRC Enforcement Policy. You are required to
respond to this letter and should follow the instructions specified in the enclosed Notice when
preparing your response. The NRC will use your response, in part, to determine whether further
enforcement action is necessary to ensure compliance with regulatory requirements.
This report documents eight additional NRC-identified and self-revealing findings of very low
safety significance (Green). Seven of these findings were determined to involve violations of
NRC requirements. However, because of the very low safety significance, and because they
are entered into your corrective action program, the NRC is treating these findings as noncited
violations, consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest the
violations or the significance of the noncited violations, you should provide a response within
30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear
Entergy Operations, Inc.
- 2 -
Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with
copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 612 E.
Lamar Blvd, Suite 400, Arlington, TX 76011-4125; the Director, Office of Enforcement, U.S.
Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident
Inspector at the Arkansas Nuclear One facility. In addition, if you disagree with the crosscutting
aspect assigned to any finding in this report, you should provide a response within 30 days of
the date of this inspection report, with the basis for your disagreement, to the Regional
Administrator, Region IV, and the NRC Resident Inspector at Arkansas Nuclear One.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, and its
enclosure, will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records component of NRCs document system (ADAMS).
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the
Public Electronic Reading Room).
Sincerely,
/RA/
Jeffrey A. Clark, P.E.
Chief, Project Branch E
Division of Reactor Projects
Dockets: 05000313; 05000368
Enclosures: Notice of Violation
NRC Inspection Report 05000313/2010004; 05000368/2010004
w/Attachment: Supplemental Information
cc w/Enclosures:
Senior Vice President
& Chief Operating Officer
Entergy Operations, Inc.
P.O. Box 31995
Jackson, MS 39286-1995
Vice President, Oversight
Entergy Operations, Inc.
P.O. Box 31995
Jackson, MS 39286-1995
Entergy Operations, Inc.
- 3 -
Stephanie Pyle, Acting Manager, Licensing
Arkansas Nuclear One
1448 SR 333
Russellville, AR 72802
Joseph A. Aluise
Associate General Counsel - Nuclear
Entergy Services, Inc
639 Loyola Avenue
New Orleans, LA 70113
Senior Manager, Nuclear Safety & Licensing
Entergy Nuclear Operations
P.O. Box 31995
Jackson, MS 39286-1995
Chief, Radiation Control Section
4815 West Markham Street, Slot 30
Little Rock, AR 72205-3867
Jim E. Gibson
County Judge of Pope County
100 West Main Street
Russellville, AR 72801
Radiation Control Section
4815 West Markham Street, Slot 30
Little Rock, AR 72205-3867
David E. Maxwell, Director
Arkansas Department of Emergency
Management, Bldg. 9501
Camp Joseph T. Robinson
North Little Rock, AR 72199
Chief, Technological Hazards
Branch
FEMA Region VI
800 North Loop 288
Federal Regional Center
Denton, TX 76209
Entergy Operations, Inc.
- 4 -
Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
Deputy Regional Administrator (Chuck.Casto@nrc.gov)
DRP Director (Kriss.Kennedy@nrc.gov)
DRP Deputy Director (Anton.Vegel@nrc.gov)
DRS Director (Roy.Caniano@nrc.gov)
DRS Deputy Director (Troy.Pruett@nrc.gov)
Senior Resident Inspector (Alfred.Sanchez@nrc.gov)
Resident Inspector (Jeffrey.Josey@nrc.gov)
Resident Inspector (Jeff.Rotton@nrc.gov)
Branch Chief, DRP/E (Jeff.Clark@nrc.gov)
Senior Project Engineer, DRP/E (Ray.Azua@nrc.gov)
Project Engineer (William.Schaup@nrc.gov)
Project Engineer (Jim. Melfi@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Public Affairs Officer (Lara.Uselding@nrc.gov)
Project Manager (Kaly.Kalyanam@nrc.gov)
Branch Chief, DRS/TSB (Michael.Hay@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
OEMail Resource
ROPreports
DRS/TSB STA (Dale.Powers@nrc.gov)
OEDO RIV Coordinator (Geoffrey.Miller@nrc.gov)
Executive Technical Assistant (John.Giessner@nrc.gov)
R:\\_REACTORS\\_ANO\\2010\\ANO2010004-RPT-AAS.docx ML
ADAMS: No 5Yes
5 SUNSI Review Complete
Reviewer Initials: JC
5Publicly Available
5 Non-Sensitive
Non-publicly Available
Sensitive
RIV:SRI/DRP/B RI/DRP/B
RI/DRP/B
SPE/DRP/PBE C:DRS/PSB2
C:DRS/EB1
ASanchez
JJosey
JRotton
RAzua
GWerner
TFarnholtz
/RA/ T-Clark
/RA/ T-Clark
/RA/ T-Clark
/RA/ T-Clark
/RA/
/RA/
11/12/2010
11/12/2010
11/12/2010
11/12/2010
11/09/2010
11/08/2010
C:DRS/EB2
C:DRS/TSB
C:DRS/OB
C:DRS/PSB1 SEO:ORA/OE
C:DRP/PBE
NOKeefe
MHay
MHaire
MShannon
RKellar
JClark
/RA/
/RA/
/RA/KClayton for
/RA/
/RA/ T-Azua
/RA/
11/08/2010
11/09/2010
11/09/2010
11/09/2010
11/11/2010
11/12/2010
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
Entergy Operations, Inc.
Docket No: 50-313
Docket No: 50-368
Arkansas Nuclear One Station License
No: DPR-51
No: NPF-6
EA 10-233
During an NRC inspection conducted on July 1through September 30, 2010, a violation of NRC
requirements was identified. In accordance with the NRC Enforcement Policy, the violation is
listed below:
Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion V,
Instructions, Procedures, and Drawings, requires, in part, that activities affecting
quality shall be prescribed by documented instructions, procedures or drawings,
of a type appropriate to the circumstances and shall be accomplished in
accordance with these instructions, procedures, or drawings.
Arkansas Nuclear One Procedure EN-MA-118, Foreign Material Exclusion,
Revision 6 requires the establishment of a Foreign Material Exclusion Zone 1
when loss of foreign material exclusion integrity could result in fuel failure,
reduced system safety, station availability, or significant cost for recovery.
Section 5.11, FME Zone 1 Requirements, of the same procedure, states in part
that for Foreign Material Exclusion Zone 1, the Foreign Material Exclusion Monitor
shall control personnel and material access to the Foreign Material Exclusion
zone.
Contrary to the above, between October 31, 2008, and September 2, 2010, Arkansas
Nuclear One failed to ensure Foreign Material was controlled in accordance with the
requirements of Procedure EN-MA-118. Specifically, the inspectors identified multiple
occasions where the licensee personnel failed to implement appropriate foreign material
exclusion controls (e.g., failure to appropriately log material in to and out of the area) in
Foreign Material Exclusion Zone 1 areas around safety-related equipment as required by
station procedure. Additionally, these failures had the potential of having a negative
impact on safety-related components.
This violation is associated with a Green Significance Determination Process finding.
Pursuant to the provisions of 10 CFR 2.201, Entergy Operations, Inc. is hereby required to
submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional
Administrator, Region IV, and a copy to the NRC Resident Inspector at the facility that is the
subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation
(Notice). This reply should be clearly marked as a "Reply to Notice of Violation EA-10-233," and
should include: (1) the reason for the violation, or, if contested, the basis for disputing the
violation or severity level, (2) the corrective steps that have been taken and the results
- 1 -
Enclosure 1
- 2 -
Enclosure 1
achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date
when full compliance will be achieved. Your response may reference or include previous
docketed correspondence, if the correspondence adequately addresses the required response.
If an adequate reply is not received within the time specified in this Notice, an order or a
Demand for Information may be issued as to why the license should not be modified,
suspended, or revoked, or why such other action as may be proper should not be taken. Where
good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, U. S. Nuclear Regulatory
Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs document system (ADAMS), accessible from the
NRC website at http://www.nrc.gov/reading-rm/pdr.html or http://www.nrc.gov/reading-
rm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or
safeguards information so that it can be made available to the public without redaction. If
personal privacy or proprietary information is necessary to provide an acceptable response,
then please provide a bracketed copy of your response that identifies the information that
should be protected and a redacted copy of your response that deletes such information. If you
request withholding of such material, you must specifically identify the portions of your response
that you seek to have withheld and provide in detail the basis for your claim of withholding (e.g.,
explain why the disclosure of information will create an unwarranted invasion of personal
privacy or provide the information required by 10 CFR 2.390(b) to support a request for
withholding confidential commercial or financial information). If safeguards information is
necessary to provide an acceptable response, please provide the level of protection described
in 10 CFR 73.21.
Dated this 12th day of November 2010.
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Dockets:
05000313, 05000368
Licenses:
Report:
05000313/2010004 and 0500368/2010004
Licensee:
Entergy Operations, Inc.
Facility:
Arkansas Nuclear One, Units 1 and 2
Location:
Junction of Hwy. 64 West and Hwy. 333 South
Russellville, Arkansas
Dates:
July 1 through September 30, 2010
Inspectors:
A. Sanchez, Senior Resident Inspector
J. Josey, Resident Inspector
J. Rotton, Resident Inspector
C. Osterholtz, Senior Operations Engineer
K. Clayton, Senior Operations Engineer
T. Pate, Operations Engineer
D. Strickland, Operations Engineer
L. Ricketson, P.E., Senior Health Physicist
C. Graves, Health Physicist
D. Stearns, Health Physicist
Approved By:
Jeff Clark, P.E., Chief, Project Branch E
Division of Reactor Projects
- 1 -
Enclosure 2
SUMMARY OF FINDINGS
IR 05000313/2010004; 05000368/2010004; 07/01-09/30/2010; Arkansas Nuclear One,
Integrated Resident and Regional Report; Licensed Operator Requalification Program;
Operability Evaluations; Plant Modifications; Post Maintenance Testing; Refuel and Other
Outage Activities; Surveillance Testing; Radioactive Solid Waste Processing, and Radioactive
Material Handling, Storage, and Transportation; and Identification and Resolution of Problems.
The report covered a 3-month period of inspection by resident inspectors and announced
baseline inspections by regional inspectors. One Green cited violation, one Green finding and
seven Green noncited violations were identified. The significance of most findings is indicated
by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609,
Significance Determination Process. Crosscutting aspects are determined using Inspection
Manual Chapter 0310, "Components within the Cross Cutting Areas." Findings for which the
significance determination process does not apply may be Green or be assigned a severity level
after NRC management review. The NRC's program for overseeing the safe operation of
commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
Revision 4, dated December 2006.
A.
NRC-Identified Findings and Self-Revealing Findings
Cornerstone: Initiating Events
Green. The inspectors documented a self-revealing finding for station electrical
maintenance personnel's failure to adequately implement station Procedure EN-
WM-102, Work Implementation and Closeout, Revision 4. Specifically, station
personnel performing Work Order 00182908-01, removal/reinstallation of the
C-8A isophase fan motor, did not stop work and get a scope change for the work
order when a condition that was not identified in the work order was discovered.
This issue was entered into the licensee's corrective action program as Condition
Report CR-ANO-1-2010-2260.
The performance deficiency was determined to be more than minor because it
affected the human performance attribute of the Initiating Events Cornerstone,
and it directly affected the cornerstone objective to limit the likelihood of those
events that upset plant stability during power operations. Using Manual
Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings,
the inspectors determined that the finding was determined to have very low
safety significance because it did not contribute to both the likelihood of a reactor
trip and the likelihood that mitigation equipment or function would not be
available. The finding was determined to have a crosscutting aspect in the area
of Human Performance, associated with work practices in that the licensee failed
to communicate human error prevention techniques, such as holding pre-job
briefs, self- and peer-checking, and proper documentation of activities H.4(a)
(Section 1R19).
- 2 -
Enclosure 2
Green. The inspectors documented a self-revealing noncited violation of Unit 1
Technical Specification 5.4.1.a for the failure to follow Procedure EN-OP-102,
Protective and Caution Tagging, Revision 12. Specifically, a maintenance
tagout holder signed off a tagout prior to all work being complete, which led to the
removal of the clearance. This resulted in draining the pressurizer to the
containment basement floor instead of to a drain tank. This issue was entered
into the corrective action program as Condition Report CR-ANO-1-2010-1013.
Failure of station personnel to follow Procedure EN-OP-102, Protective and
Caution Tagging, Revision 12 was a performance deficiency. The performance
deficiency was associated with the Initiating Events Cornerstone. The
performance deficiency was determined to be more than minor because if left
uncorrected it could lead to a more significant safety issue. Specifically, the
continued failure to follow this procedure could lead to the inappropriate release
of systems and equipment to other organizations when these systems or
equipment are not capable of performing their function. This is therefore a
finding. Using NRC Manual Chapter 0609, Significance Determination Process,
Appendix G, "Shutdown Operations Significance Determination," Attachment 1,
the finding was determined to have very low safety significance because the
finding did not affect core heat removal, inventory control, power availability,
containment control or reactivity guidelines. The finding was determined to have
a crosscutting aspect in the area of human performance, associated with work
practices in that the licensee did not ensure supervisory and management
oversight of work activities such that nuclear safety is supported. Specifically,
instead of supplying appropriate guidance and supervision for the workers in the
field, the mechanical war room coordinators actions resulted in the failure to
follow procedure by convincing the mechanical lead to sign off on the tagout
before the work had been completed H.4(c) (Section 4OA2.5).
Green. The inspectors identified a noncited violation of 10 CFR Part 50,
Appendix B, Criterion V, at Unit 2. The violation was associated with the biennial
written exam overlap for the weeks four, five, and six written examinations
administered by the facility during the weeks of July 5-9, 2010, July 12-16, 2010,
and July 19-23, 2010. The issues were documented in licensee-initiated
Condition Report CR-ANO-2-2010-01460, which resulted in the licensee
removing five questions from the week four exam and writing new exams for
weeks five and six and administering them prior to the cycle end date of July 31,
2010.
The excessive overlap of the written exam portion of the Unit 2 2010 biennial
written exams was a performance deficiency in that the licensee failed to follow
their established requalification procedures. Specifically, in 2010 some operators
were tested using requalification written exams that repeated greater that
50 percent of the questions that had already been used in the earlier exam
weeks. This finding was more than minor because if left uncorrected it could
have led to a more significant safety concern, in that, licensed operations
personnel could be returned to licensed duties without receiving a procedurally
- 3 -
Enclosure 2
valid examination. The performance deficiency was associated with the Initiating
Events Cornerstone. The inspectors applied Manual Chapter 0609 Significant
Determination Process, Appendix I, Licensed Operator Requalification
Significance Determination Process, and determined that the finding should be
dispositioned as a Green noncited violation. The finding was assessed as having
very low safety significance because: (1) the overlap issues were found during
the biennial examinations of the operators, (2) there were no actual
consequences due to the inadequate examinations, (3) the applicable crews
were re-evaluated once the issues were found, (4) this issue did not exist on the
last biennial written exams in 2008 and did not occur on any of the Unit 1 biennial
written examinations, and (5) the performance on these new exams was
satisfactory. This finding has a crosscutting aspect in the area of work practices
because the licensee did not ensure that supervisory and management oversight
of work activities supported nuclear safety because the 2010 Unit 2 written exam
overlap issues were not caught during the supervisory review and approval prior
to administration of the examinations or prior to the start of this inspection
H.4(c) (Section 1R11).
Cornerstone: Mitigating Systems
Green. The inspectors identified a noncited violation of 10 CFR Part 50,
Appendix B, Criterion XVI, Corrective Action, for the failure of the licensee to
promptly identify and correct a known condition adverse to quality associated
with the susceptibility of the emergency diesel generators heating, ventilating
and air conditioning ducting to loading effects caused by natural phenomena,
such as tornados. Specifically, while performing a review in response to an NRC
generic communication, the licensee determined that they could not demonstrate
the ability of the station's emergency diesel generators' heating, ventilating and
air conditioning ducting to withstand a tornado depressurization event. However
no actions were taken to correct or mitigate this issue at the time of discovery.
The licensee entered this issue in their corrective action program as Condition
Report CR-ANO-C-2009-2296.
Failure to promptly identify and correct a known condition adverse to quality
associated with the susceptibility of the Unit 1 emergency diesel generators'
heating, ventilating and air conditioning ducting to loading effects caused by
natural phenomena, tornados, was a performance deficiency. The performance
deficiency was determined to be more than minor because it was associated with
the protection against external events attribute of the Mitigating Systems
Cornerstone, and affected the associated cornerstone objective to ensure the
availability, reliability, and capability of systems that respond to initiating events
to prevent undesirable consequences, and is therefore a finding. Using Manual
Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings,
the finding was determined to have very low safety significance because the
finding: (1) was not a design or qualification issue confirmed not to result in a
loss of operability or functionality; (2) did not represent an actual loss of safety
function of the system or train; (3) did not result in the loss of one or more trains
of nontechnical specification equipment; and (4) did not screen as potentially risk
- 4 -
Enclosure 2
significant due to a seismic, flooding, or severe weather initiating event. The
finding was determined to have a crosscutting aspect in the area of human
performance, associated with decision making in that the licensee failed to use
conservative assumptions in decision making and adopt a requirement to
demonstrate that the proposed action is safe in order to proceed rather than a
requirement to it is unsafe in order to disapprove the action H.1(b)
(Section 1R15).
Green. The inspectors documented a self-revealing noncited violation of 10 CFR
Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to
assure that the applicable design basis for applicable structures, systems, and
components were correctly translated into specifications, procedures, and
instructions. Specifically, during initial plant installation, the licensee failed to
correctly identify the effect redundant protective equipment interlocks could have
on maintaining operability of VCH-4B design requirements upon a loss of normal
non-safety related room cooling. This resulted in VCH-4B, emergency
switchgear chiller, not being able to start and perform its design function due to a
combination of high room temperature due to loss of normal non-safety related
cooling, and normally energized compressor oil heaters which led to a high
compressor oil temperature switch actuation that caused a lockout of the chiller
that would have prevented a chiller start. The licensee entered this issue in their
corrective action program as Condition Report CR-ANO-1-2010-2815.
Failure to ensure that design requirements were correctly translated into installed
plant equipment was a performance deficiency. The performance deficiency was
determined to be more than minor because it was associated with the equipment
performance attribute of the Mitigating Systems Cornerstone, and affected the
associated cornerstone objective to ensure availability, reliability, and capability
of systems that respond to initiating events to prevent undesirable
consequences, and is therefore a finding. Using Manual Chapter 0609.04,
Phase 1 - Initial Screening and Characterization of Findings, the finding was
determined to have very low safety significance because: (1) the finding was not
a qualification deficiency that resulted in a loss of functionality of chiller VCH-4B;
(2) it did not lead to an actual loss of safety function of the system or train; (3) it
did not result in an actual loss of safety function of a single train for greater than
its technical specification allowed outage time; (4) it did not represent an actual
loss of safety function of one or more non- technical specification trains of
equipment designated as risk-significant per 10 CFR 50.65, for greater than
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; (5) it did not screen as potentially risk-significant due to a seismic,
flooding, or severe weather initiating event. The inspectors determined that since
the licensee had not recently re-evaluated the design of the emergency
switchgear room chillers high oil temperature lockout; this finding did not
represent current plant performance, and therefore did not have a crosscutting
aspect associated with it (Section 1R22).
Green. The inspectors documented a self-revealing noncited violation of 10 CFR
Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure
- 5 -
Enclosure 2
to promptly identify and correct a known condition adverse to quality associated
with the improper setup of the dead band of service water flow control
valve CV-6034 for cold weather operation. This resulted in the pressure control
valve not properly modulating in response to pressure control inputs, resulting in
emergency switchgear chiller VCH-4A tripping on high discharge pressure. The
licensee entered this issue in their corrective action program as Condition
Report CR-ANO-1-2009-2212.
Failure to promptly identify and correct a known condition adverse to quality
associated with the improper setup of the dead band of service water flow control
valve CV-6034 for cold weather operation was a performance deficiency. The
performance deficiency was determined to be more than minor because it was
associated with the equipment performance attribute of the Mitigating Systems
Cornerstone, and affected the associated cornerstone objective to ensure the
availability, reliability, and capability of systems that respond to initiating events
to prevent undesirable consequences, and is therefore a finding. Using Manual
Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings,
the finding was determined to have very low safety significance because: (1) the
finding was not a qualification deficiency that resulted in a loss of functionality of
chiller VCH-4A; (2) it did not lead to an actual loss of safety function of the
system or train; (3) it did not result in an actual loss of safety function of a single
train for greater than its technical specification allowed outage time; (4) it did not
represent an actual loss of safety function of one or more non-technical
specification trains of equipment designated as risk-significant per 10 CFR 50.65,
for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and (5) it did not screen as potentially risk-significant
due to a seismic, flooding, or severe weather initiating event. The finding was
determined to have a crosscutting aspect in the area of human performance,
associated with decision making in that, although the licensee had identified the
vulnerability of the VCH-4A chiller, decided not to pursue the corrective actions to
adjust the dead band for valve CV-6034 and resulted in the subsequent improper
operation of the valve H.1(b) (Section 1R18).
Green. The inspectors identified a cited violation of 10 CFR Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, associated with the
licensees failure to adequately implement Procedure EN-MA-118, Foreign
Material Exclusion, Revision 5/6. Specifically, between October 31, 2008, and
September 02, 2010, inspectors identified multiple occasions where licensee
personnel failed to implement appropriate foreign material exclusion controls in
Zone 1 areas around safety related equipment (e.g., failure to appropriately log
material in to and out of the zone) as required by station procedure. Each
identified instance was a repeat occurrence of previously identified issues that
were documented as NRC identified violations in previous inspection reports in
2008, 2009, and early 2010. Measures established by Arkansas Nuclear One to
address these previously identified noncited violations failed to restore
compliance within a reasonable time after these violations were identified.
Finally, these failures had the potential of having a negative impact on safety
related components such as fuel failure, safety system reliability and safety
- 6 -
Enclosure 2
related equipment availability. This issue was entered into the licensee's
corrective action program as Condition Reports CR-ANO-1-2010-3155,
CR-ANO-2-2010-1839, and CR-ANO-C-2010-2192.
The performance deficiency was determined to be more than minor because it
was associated with the human performance attribute of the Mitigating Systems
Cornerstone, and affected the associated cornerstone objective to ensure the
availability, reliability, and capability of systems that respond to initiating events
to prevent undesirable consequences, and is therefore a finding. Using the
Manual Chapter 0609, Significance Determination Process, Phase 1
Worksheets, the finding was determined to have very low safety significance
because the finding: (1) was not a design or qualification issue confirmed not to
result in a loss of operability or functionality; (2) did not represent an actual loss
of safety function of the system or train; (3) did not result in the loss of one or
more trains of nontechnical specification equipment; and (4) did not screen as
potentially risk significant due to a seismic, flooding, or severe weather initiating
event. The finding was determined to have a crosscutting aspect in the area of
problem identification and resolution, associated with the corrective action
program, P.1(d), in that the licensee takes appropriate corrective actions to
address safety issues and adverse trends in a timely manner, commensurate
with their safety significance and complexity (Section 1R20).
Green. The inspectors identified a noncited violation of 10 CFR Part 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, for station
planning personnel's failure to adequately implement station
Procedure EN-FAP-WM-011, Work Planning Standard, Revision 0, and
EN WM-105, Planning, Revision 6. Specifically, from August 3-19, 2010,
multiple examples were identified where work orders used to perform
maintenance activities on safety related equipment were incorrectly classified as
reference work orders, referenced technical material that did not contain
guidance for the prescribed task, or did not contain sufficient detail or direction to
accomplish the maintenance activity as written. This issue was entered into the
licensee's corrective action program as Condition Reports CR-ANO-C-2010-
1962, CR-ANO-C-2010-1964, CR-ANO-2-2010-1736, CR-ANO-C-2010-2114,
CR-ANO-C-2010-2119, and CR-ANO-C-2010-2140.
The performance deficiency was determined to be more than minor because if
left uncorrected, the continued practice of generating inadequate work orders for
maintenance activities on safety-related equipment would have the potential to
leave risk significant equipment in a degraded condition without the knowledge
and approval of site management and operations personnel, and is therefore a
finding. The performance deficiency was associated with the Mitigating Systems
Cornerstone. Using Manual Chapter 0609.04, Phase 1 - Initial Screening and
Characterization of Findings, the finding was determined to have very low safety
significance because the finding: (1) was not a design or qualification issue
confirmed not to result in a loss of operability or functionality; (2) did not
represent an actual loss of safety function of the system or train; (3) did not result
- 7 -
Enclosure 2
in the loss of one or more trains of nontechnical specification equipment; and
(4) did not screen as potentially risk significant due to a seismic, flooding, or
severe weather initiating event. The finding was determined to have a
crosscutting aspect in the area of human performance, associated with work
practices H.4(b) in that the licensee defines and effectively communicates
expectations regarding procedural compliance and personnel follow procedures.
(Section 4OA2).
Cornerstone: Public Radiation Safety
Green. The inspectors identified a noncited violation of 10 CFR 20.2006(b) for
failure to ship radioactive waste with an accurate manifest. On May 19, 2009,
the licensee shipped 20 Unit 2 spent fuel pool filters to a waste processor for
segregation. The licensee was notified on June 1, 2009, that dose rate on one
filter was almost twice the licensee reported dose rate (38 rem/hr vice 20 rem/hr).
The total activity of the shipment based on the higher dose rate was
approximately three times more than reported on the shipping manifest. Based
on the inspectors finding, the licensee corrected the shipping manifest and
documented this issue in the corrective action program as Condition
Report CR-ANO-C-2010-1866.
Failure to include the correct total radioactivity on a waste manifest is a
performance deficiency. The finding is greater than minor because it was
associated with the Public Radiation Safety Cornerstone attribute of program and
process (transportation program), and affected the cornerstone objective, in that,
it provided incorrect information as part of hazard communication which could
increase public dose. Using the public radiation safety significance determination
process, the inspectors determined the finding had very low safety significance
because: (1) radiation limits were not exceeded, (2) there was no breach of a
package during transit, (3) it did not involve a certificate of compliance issue,
(4) it was not a low level burial ground nonconformance, and (5) it did not involve
a failure to make notifications or provide emergency information. Additionally,
this finding had a crosscutting aspect in the area of corrective action program
because the licensee did not set a low threshold for identifying and correcting
issues P.1(a) (Section 2RS08).
B.
Other Findings
None.
- 8 -
Enclosure 2
REPORT DETAILS
Summary of Plant Status
Unit 1 operated at 100 percent power for the entire period.
Unit 2 began the inspection period operating at 100 percent power. On August 23, 2010, Unit 2
performed a technical specification required shutdown to affect repairs to emergency diesel
generator 2. On September 4, 2010, Unit 2 returned to 100 percent power and remained at
100 percent for the rest of the period.
1.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and
1R04 Equipment Alignments (71111.04)
.1
Partial Walkdown
a.
Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant
systems:
August 4-5, 2010, Unit 2, train B containment spray pump while train A was out
of service for maintenance activities
August 12, 2010, Unit 2, emergency diesel generator 1 and alternate AC
generator when Unit 2 emergency diesel generator 2 was out of service for
extended maintenance activity
August 23, 2010, Unit 1, motor-driven emergency feedwater pump P-7B while
turbine-driven emergency feedwater pump P-7A was out of service for planned
maintenance
September 13, 2010, Unit 1, train A low pressure safety injection pump while
train B was out of service for planned maintenance activities
September 23, 2010, Unit 2, motor-driven emergency feedwater pump 2P-7B
while turbine-driven emergency feedwater pump 2P-7A was out of service for
planned maintenance
The inspectors selected these systems based on their risk significance relative to the
reactor safety cornerstones at the time they were inspected. The inspectors attempted
to identify any discrepancies that could affect the function of the system, and, therefore,
potentially increase risk. The inspectors reviewed applicable operating procedures,
system diagrams, Safety Analysis Report, technical specification requirements,
administrative technical specifications, outstanding work orders, condition reports, and
- 9 -
Enclosure 2
the impact of ongoing work activities on redundant trains of equipment in order to identify
conditions that could have rendered the systems incapable of performing their intended
functions. The inspectors also inspected accessible portions of the systems to verify
system components and support equipment were aligned correctly and operable. The
inspectors examined the material condition of the components and observed operating
parameters of equipment to verify that there were no obvious deficiencies. The
inspectors also verified that the licensee had properly identified and resolved equipment
alignment problems that could cause initiating events or impact the capability of
mitigating systems or barriers and entered them into the corrective action program with
the appropriate significance characterization. Specific documents reviewed during this
inspection are listed in the attachment.
These activities constitute completion of five (5) partial system walkdown samples as
defined in Inspection Procedure 71111.04-05.
b.
Findings
No findings were identified.
.2
Complete Walkdown
a.
Inspection Scope
During the month of April 2010 (during Refueling Outage 1R22) and week of
September 26, 2010, the inspectors performed a complete system alignment inspection
of the Unit 1 low pressure injection/decay heat removal systems to verify the functional
capability of the system. This system was selected because it was considered both
safety significant and risk significant in the licensees probabilistic risk assessment. The
inspectors walked down the system to review mechanical and electrical equipment line
ups, electrical power availability, system pressure and temperature indications, as
appropriate, component labeling, component lubrication, component and equipment
cooling, hangers and supports, operability of support systems, and to ensure that
ancillary equipment or debris did not interfere with equipment operation. A review of a
sample of past and outstanding work orders (WOs) was performed to determine whether
any deficiencies significantly affected the system function. In addition, the inspectors
reviewed the corrective action program database to ensure that system equipment
alignment problems were being identified and appropriately resolved. Documents
reviewed are listed in the attachment.
On September 5, 2010, the inspectors performed a complete system alignment
inspection of the Unit 1 reactor building spray system to verify the functional capability of
the system. The inspectors selected this system because it was considered both safety-
significant and risk-significant in the licensees probabilistic risk assessment. The
inspectors walked down the system to review mechanical and electrical equipment line
ups, electrical power availability, system pressure and temperature indications, as
appropriate, component labeling, component lubrication, component and equipment
cooling, hangers and supports, operability of support systems, and to ensure that
ancillary equipment or debris did not interfere with equipment operation. The inspectors
- 10 -
Enclosure 2
reviewed a sample of past and outstanding work orders to determine whether any
deficiencies significantly affected the system function. In addition, the inspectors
reviewed the corrective action program database to ensure that system equipment-
alignment problems were being identified and appropriately resolved. Specific
documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of two (2) complete system walkdown samples as
defined in Inspection Procedure 71111.04-05.
b.
Findings
No findings were identified.
3
System Walkdown associated with Temporary Instruction (TI) 2515/177, Managing Gas
Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment
Spray Systems.
a.
Inspection Scope
During the month of April 2010 (during Refueling Outage 1R22) and week of
September 26, 2010, the inspectors conducted a walkdown of the Unit 1 trains A and B
low pressure injection/decay heat removal systems in sufficient detail to reasonably
assure the acceptability of the licensees walkdowns (TI 2515/177, Section 04.02.d).
In addition, the inspectors verified that the licensee had isometric drawings that describe
the Unit 1, trains A and B, low pressure/decay heat removal system configurations and
had acceptably confirmed the accuracy of the drawings (TI 2515/177, Section 04.02.a).
The inspectors verified the following related to the isometric drawings:
High point vents were identified. High points that do not have vents were acceptably
recognizable. Other areas where gas can accumulate and potentially impact subject
system operability, such as at orifices in horizontal pipes, isolated branch lines, heat
exchangers, improperly sloped piping, and under closed valves, were acceptably
described in the drawings or in referenced documentation. Horizontal pipe centerline
elevation deviations and pipe slopes in nominally horizontal lines that exceed specified
criteria were identified. All pipes and fittings were clearly shown. The drawings were up-
to-date with respect to recent hardware changes and that any discrepancies between
as-built configurations and the drawings were documented and entered into the
corrective action program for resolution.
The inspectors verified that piping and instrumentation diagrams accurately described
the subject systems, that they were up-to-date with respect to recent hardware changes,
and any discrepancies between as-built configurations, the isometric drawings, and the
piping and instrumentation diagrams were documented and entered into the corrective
action program for resolution (TI 2515/177, Section 04.02.b).
Documents reviewed are listed in the attachment to this report.
- 11 -
Enclosure 2
This inspection effort counts towards the completion of TI 2515/177 which will be closed
in a later inspection report.
b.
Findings
No findings were identified.
1R05 Fire Protection (71111.05)
.1
Quarterly Fire Inspection Tours
a.
Inspection Scope
The inspectors conducted fire protection walkdowns that were focused on availability,
accessibility, and the condition of firefighting equipment in the following risk-significant
plant areas:
September 9, 2010, Unit 2, Fire Zone 2137-I, Upper south electrical penetration
room
September 9, 2010, Unit 2, Fire Zone 2098-L, Cable spreading room
September 30, 2010, Unit 1, Fire Zone 86-G, North emergency diesel generator
room
September 30, 2010, Unit 1, Fire Zone 87-H, South emergency diesel generator
room
The inspectors reviewed areas to assess if licensee personnel had implemented a fire
protection program that adequately controlled combustibles and ignition sources within
the plant; effectively maintained fire detection and suppression capability; maintained
passive fire protection features in good material condition; and had implemented
adequate compensatory measures for out of service, degraded or inoperable fire
protection equipment, systems, or features, in accordance with the licensees fire plan.
The inspectors selected fire areas based on their overall contribution to internal fire risk
as documented in the plants Individual Plant Examination of External Events with later
additional insights, their potential to affect equipment that could initiate or mitigate a
plant transient, or their impact on the plants ability to respond to a security event. Using
the documents listed in the attachment, the inspectors verified that fire hoses and
extinguishers were in their designated locations and available for immediate use; that
fire detectors and sprinklers were unobstructed; that transient material loading was
within the analyzed limits; and fire doors, dampers, and penetration seals appeared to
be in satisfactory condition. The inspectors also verified that minor issues identified
during the inspection were entered into the licensees corrective action program.
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of four (4) quarterly fire-protection inspection
samples as defined in Inspection Procedure 71111.05-05.
- 12 -
Enclosure 2
b.
Findings
No findings were identified.
1R06 Flood Protection Measures (71111.06)
a.
Inspection Scope
The inspectors reviewed the Safety Analysis Report, the flooding analysis, and plant
procedures to assess susceptibilities involving internal flooding; reviewed the corrective
action program to determine if licensee personnel identified and corrected flooding
problems; inspected underground bunkers/manholes to verify the adequacy of sump
pumps, level alarm circuits, cable splices subject to submergence, and drainage for
bunkers/manholes; and verified that operator actions for coping with flooding can
reasonably achieve the desired outcomes. The inspectors also inspected the one area
listed below to verify the adequacy of equipment seals located below the flood line, floor
and wall penetration seals, watertight door seals, common drain lines and sumps, sump
pumps, level alarms, and control circuits, and temporary or removable flood barriers.
Specific documents reviewed during this inspection are listed in the attachment.
September 30, 2010, Unit 1, Area 38-Y, Emergency feedwater pump room
These activities constitute completion of one (1) flood protection measures inspection
sample as defined in Inspection Procedure 71111.06-05.
b.
Findings
No findings were identified.
1R11 Licensed Operator Requalification Program (71111.11)
.1
Quarterly Review
a.
Inspection Scope
On September 15, 2010, the inspectors observed a crew of licensed operators in the
plants simulator to verify that operator performance was adequate, evaluators were
identifying and documenting crew performance problems, and training was being
conducted in accordance with licensee procedures. The inspectors evaluated the
following areas:
Licensed operator performance
Crews clarity and formality of communications
Crews ability to take timely actions in the conservative direction
- 13 -
Enclosure 2
Crews prioritization, interpretation, and verification of annunciator alarms
Crews correct use and implementation of abnormal and emergency procedures
Control board manipulations
Oversight and direction from supervisors
Crews ability to identify and implement appropriate technical specification
actions and emergency plan actions and notifications
The inspectors compared the crews performance in these areas to pre-established
operator action expectations and successful critical task completion requirements.
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one (1) quarterly licensed-operator
requalification program sample as defined in Inspection Procedure 71111.11.
b.
Findings
No findings were identified.
.2
Biennial Inspection (Units 1 and 2)
The licensed operator requalification program involves two training cycles that are
conducted over a 2-year period. In the first cycle, the annual cycle, the operators are
administered an operating test consisting of job performance measures and simulator
scenarios. In the second part of the training cycle, the biennial cycle, operators are
administered an operating test and a comprehensive written examination. Unit 1 was in
the first part of the training cycle while Unit 2 was in the second part of the training cycle.
The examiners observed the associated training cycles for both units during this period.
a.
Inspection Scope
To assess the performance effectiveness of the licensed operator requalification
program, the inspectors conducted personnel interviews, reviewed both the operating
tests and written examinations, and observed ongoing operating test activities.
The inspectors interviewed 12 licensee personnel, consisting of 8 operators,
2 instructors, and 2 training supervisors, to determine their understanding of the policies
and practices for administering requalification examinations. The inspectors also
reviewed operator performance on the written exams and operating tests. These
reviews included observations of portions of the operating tests by the inspectors. The
operating tests observed included six job performance measures and five scenarios that
were used in the current biennial requalification cycle. These observations allowed the
inspectors to assess the licensee's effectiveness in conducting the operating test to
ensure operator mastery of the training program content. The inspectors also reviewed
medical records of 10 licensed operators for conformance to license conditions and the
- 14 -
Enclosure 2
licensees system for tracking qualifications and records of license reactivation for
8 operators.
The results of these examinations were reviewed to determine the effectiveness of the
licensees appraisal of operator performance and to determine if feedback of
performance analyses into the requalification training program was being accomplished.
The inspectors interviewed members of the training department and reviewed minutes of
training review group meetings to assess the responsiveness of the licensed operator
requalification program to incorporate the lessons learned from both plant and industry
events. Examination results were also assessed to determine if they were consistent
with the guidance contained in NUREG 1021, "Operator Licensing Examination
Standards for Power Reactors," Revision 9, Supplement 1, and NRC Inspection Manual
Chapter 0609, Appendix I, Operator Requalification Human Performance Significance
Determination Process.
In addition to the above, the inspectors reviewed examination security measures,
simulator fidelity and existing logs of simulator deficiencies.
On August 10, 2010, the licensee informed the lead inspector of the following Unit 1
results:
Of the 59 total licensed operators, 2 operators have not been tested (1 RO and
1 SRO have yet to be tested due to illness)
9 of 10 crews passed the simulator portion of the operating test
56 of 57 licensed operators passed the simulator portion of the operating test
57 of 57 licensed operators passed the job performance measure portion of the
examination
The individuals that failed the simulator scenario portions of the operating test were
remediated, retested, and passed their retake operating tests.
On August 10, 2010, the licensee informed the lead inspector of the following Unit 2
results:
10 of 11 crews passed the simulator portion of the operating test
54 of 55 licensed operators passed the simulator portion of the operating test
55 of 55 licensed operators passed the job performance measure portion of the
examination
54 of 55 licensed operators passed the biennial written exam
The individuals that failed the applicable portions of the operating test were remediated,
retested, and passed their retake operating tests. The individual that failed the written
exam has been remediated and passed the retake written exam.
- 15 -
Enclosure 2
The inspectors completed (1) one inspection sample of the biennial licensed operator
requalification program as defined in Inspection Procedure 71111.11.
b.
Findings
Introduction. The inspectors identified a noncited violation of 10 CFR Part 50,
Appendix B, Criterion V, Instructions, Procedures, Drawings, at Unit 2 for failure to
follow procedures required by the requalification program in order to develop written
examinations for the biennial cycle. Specifically, the licensee exceeded the 50 percent
maximum overlap for written questions on the biennial written exams defined in their
requalification program procedures for weeks four, five, and six written examinations.
These examinations were administered by the facility during the weeks of July 5-9, 2010,
July 12-16, 2010, and July 19-23, 2010. This finding was documented in licensee-
initiated Condition Report CR-ANO-2-2010-01460, which resulted in the licensee
removing five questions from the week four exam, writing new exams for weeks five and
six and administering them prior to the cycle end date of July 31, 2010.
Description. The inspectors identified that the written exams for weeks four, five, and six
exceeded the 50 percent threshold for overlap between and among the biennial
examinations. The issue was identified while conducting the Unit 2 biennial Licensed
Operator Requalification Training Program inspection during the week of July 19, 2010.
The week four exam contained 20 repeat questions out of 35 questions, or a 57 percent
overlap. The week five and week six exams each contained 100 percent overlap.
These practices did not comply with Entergys procedural guidance, EN-TQ-114,
Section 5.7[1](g) which states that, Written examinations will contain at least 50 percent
new material. This procedure is a quality procedure and, therefore, is required to meet
10 CFR Part 50, Appendix B, criteria.
The inspectors communicated these issues to the licensee staff on July 20, 2010, and
representatives of the licensees management agreed with the NRC inspection teams
assessment of the issues. The licensee determined that the 2010 Unit 2 written exams
already administered for weeks four and five were invalid due to the excessive written
exam question overlap for weeks four, five, and six. Exam administration was
suspended for Unit 2 pending development of new exams. The licensee initiated
Condition Report CR-ANO-2-2010-01460, dated July 21, 2010, to document this issue.
The inspectors also found that many of the written exam questions which were
considered new questions were almost identical to previous exam questions. The stem
of several questions had very minor changes (i.e., a change in pressure) which changed
the correct response. The same concept was being asked with a new correct answer.
The inspectors also found that there appeared to be a goal of repeating 15 of the
35 questions on weeks three, four, five and six. The 50 percent repeat of questions is a
limit, not a goal, and minimizing the amount of overlap could have prevented this
violation.
Following the onsite visit, the NRC inspection team conducted an in-office review of the
modified week four exam and the newly written and administered week five and six
examinations and found no issues with them.
- 16 -
Enclosure 2
Analysis. The excessive overlap of the written exam portion of the Unit 2 2010 biennial
written exams was a performance deficiency in that the licensee failed to follow their
established requalification procedures. Specifically, in 2010 some operators were tested
using requalification written exams that repeated greater that 50 percent of the questions
that had already been used in the earlier exam weeks. This finding was more than
minor because if left uncorrected it could lead to a more significant safety concern, in
that, licensed operations personnel could be returned to licensed duties without
receiving a procedurally valid examination. The inspectors applied Manual Chapter 0609
Significant Determination Process, Appendix I, Licensed Operator Requalification
Significance Determination Process, and determined that the finding should be
dispositioned as a Green noncited violation. The finding was assessed as having very
low safety significance (Green) because: (1) the overlap issues were found during the
biennial examinations of the operators, (2) there were no actual consequences due to
the inadequate examinations, (3) the applicable crews were re-evaluated once the
issues were found, (4) this issue did not exist on the last biennial written exams in 2008
and did not occur on any of the Unit 1 biennial written examinations, and (5) the
performance on the newly written examinations was satisfactory.
This written exam overlap finding should have been discovered and corrected by the
licensee prior to NRC identification. The licensee should have discovered the problem
prior to the NRCs identification because: (1) similar issues were described in 2002 and
2007 industry operating experience involving exam compromises; (2) the licensee
completed a Pre-71111.11 Inspection in May 2010 that failed to identify this issue; and
(3) the practices clearly violated NRC guidance and requirements, as well as the fleet-
wide Entergy procedural guidance aimed at preventing exam compromise. Following
identification of this issue by the NRC, the licensee took immediate and substantive
corrective actions to remedy the 2010 biennial written exam overlap issues by
developing new exams and retesting the affected Unit 2 licensed operators within the
required biennial exam cycle. This finding has a crosscutting aspect in the area of work
practices because the licensee did not ensure that supervisory and management
oversight of work activities supported nuclear safety because the 2010 Unit 2 written
exam overlap issues were not caught during the supervisory review and approval prior to
administration of the examinations or prior to the start of this inspection H.4(c).
Enforcement. Title 10 of the Code of Federal Regulations Part 50, Appendix B,
Criterion V, Instructions, Procedures, Drawings, requires, in part, that, Activities
affecting quality shall be described by procedures including appropriate acceptance
criteria and those procedures shall be followed. Contrary to this requirement, Entergy
fleet-wide Procedure EN-TQ-114, Revision 3, step 5.7[1](g) was not followed in that the
Unit 2 written exams for 2010 had several exams that exceeded the 50 percent overlap
requirement. Because this finding is of very low safety significance and was entered into
the licensees corrective action program as Condition Report CR-ANO-2-2010-01460,
this violation is being treated as a noncited violation, consistent with Section VI.A.1 of
the NRC Enforcement Policy: NCV 050000368/2010004-01, Excessive Overlap of
Unit 2 Written Examinations.
- 17 -
Enclosure 2
1R12 Maintenance Effectiveness (71111.12)
a.
Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk
significant systems:
August 3, 2010, Unit 2, Emergency feedwater
September 15, 2010, Unit 1, High pressure injection system
The inspectors reviewed events such as where ineffective equipment maintenance has
resulted in valid or invalid automatic actuations of engineered safeguards systems and
independently verified the licensee's actions to address system performance or condition
problems in terms of the following:
Implementing appropriate work practices
Identifying and addressing common cause failures
Scoping of systems in accordance with 10 CFR 50.65(b)
Characterizing system reliability issues for performance
Charging unavailability for performance
Trending key parameters for condition monitoring
Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or -(a)(2)
Verifying appropriate performance criteria for structures, systems, and
components classified as having an adequate demonstration of performance
through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as
requiring the establishment of appropriate and adequate goals and corrective
actions for systems classified as not having adequate performance, as described
The inspectors assessed performance issues with respect to the reliability, availability,
and condition monitoring of the system. In addition, the inspectors verified maintenance
effectiveness issues were entered into the corrective action program with the appropriate
significance characterization. Specific documents reviewed during this inspection are
listed in the attachment.
These activities constitute completion of two (2) quarterly maintenance effectiveness
samples as defined in Inspection Procedure 71111.12-05.
- 18 -
Enclosure 2
b.
Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
a.
Inspection Scope
The inspectors reviewed licensee personnel's evaluation and management of plant risk
for the maintenance and emergent work activities affecting risk-significant and safety-
related equipment listed below to verify that the appropriate risk assessments were
performed prior to removing equipment for work:
July 6, 2010, Unit 2, Elevated risk for 2P-7B, motor driven emergency feedwater
pump unavailable for maintenance
July 26, 2010, Unit 2, Elevated risk for alternated AC diesel generator planned
maintenance activity
August 11, 2010, Unit 2, Emergency diesel generator 2K-4B planned 14-day
extended maintenance outage
August 12-13, 2010, Unit 1, Train B high pressure injection inoperable due to
planned maintenance
Week of August 23, 2010, Unit 2, Emergency diesel generator 2K-4B crankcase
vacuum issues that resulted in a technical specification required shutdown
September 17, 2010, Units 1 and 2, Evaluation of risk associated with crane
activities in the switchyard for lightning arrestor mast foundation excavation
September 23, 2010, Unit 1, Risk assessment evaluation for heavy load crane
activities in the vicinity of Unit 1 reactor building and condensate storage tank
The inspectors selected these activities based on potential risk significance relative to
the reactor safety cornerstones. As applicable for each activity, the inspectors verified
that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)
and that the assessments were accurate and complete. When licensee personnel
performed emergent work, the inspectors verified that the licensee personnel promptly
assessed and managed plant risk. The inspectors reviewed the scope of maintenance
work, discussed the results of the assessment with the licensee's probabilistic risk
analyst or shift technical advisor, and verified plant conditions were consistent with the
risk assessment. The inspectors also reviewed the technical specification requirements
and inspected portions of redundant safety systems, when applicable, to verify risk
analysis assumptions were valid and applicable requirements were met. Specific
documents reviewed during this inspection are listed in the attachment.
- 19 -
Enclosure 2
These activities constitute completion of seven (7) maintenance risk assessments and
emergent work control inspection samples as defined in Inspection
Procedure 71111.13-05.
b.
Findings
No findings were identified.
1R15 Operability Evaluations (71111.15)
a.
Inspection Scope
The inspectors reviewed the following issues:
April 10 and May 26, 2010, Unit 1, Core flood tank T-2A for gas space leakage
during the Unit 1 refueling outage
May 28, 2010, Unit 1, Emergency diesel generator 1 failure to secure from the
control room and required local operator action to secure
June 21, 2010, Unit 1, P-36C high pressure injection suction relief
valve PSV-1234 missed inservice test greater than technical specification
surveillance requirement and entry into technical specification Surveillance
Requirement 3.0.3
July 2, 2010, Unit 1, P-7A turbine driven emergency feedwater pump speed
increase
July 22, 2010, Unit 2, Emergency feedwater pump 2P-7A during erratic operation
of flow transmitter.
July 31, 2010, Unit 1, Degrading trend in reactor building pressure, actually
achieving a negative pressure
August 3, 2010, Unit 2, Excore detector channel C operability
August 9, 2010, Unit 1, Train B high pressure injection for leakage through
borated water storage tank stop check valve BW-3
August 19, 2010, Unit 1, VCH-4A emergency switchgear room chiller
September 25, 2010, Unit 1, Diesel generator ventilation systems susceptibility to
the depressurization effects of a tornado
The inspectors selected these potential operability issues based on the risk-significance
of the associated components and systems. The inspectors evaluated the technical
adequacy of the evaluations to ensure that technical specification operability was
properly justified and the subject component or system remained available such that no
- 20 -
Enclosure 2
unrecognized increase in risk occurred. The inspectors compared the operability and
design criteria in the appropriate sections of the technical specifications and Safety
Analysis Report to the licensee personnels evaluations to determine whether the
components or systems were operable. Where compensatory measures were required
to maintain operability, the inspectors determined whether the measures in place would
function as intended and were properly controlled. The inspectors determined, where
appropriate, compliance with bounding limitations associated with the evaluations.
Additionally, the inspectors also reviewed a sampling of corrective action documents to
verify that the licensee was identifying and correcting any deficiencies associated with
operability evaluations. Specific documents reviewed during this inspection are listed in
the attachment.
These activities constitute completion of ten (10) operability evaluations inspection
samples as defined in Inspection Procedure 71111.15-04
b.
Findings
Introduction. The inspectors identified a Green noncited violation of 10 CFR Part 50,
Appendix B, Criterion XVI, Corrective Action, for the failure of the licensee to promptly
identify and correct a known condition adverse to quality associated with the
susceptibility of the emergency diesel generators heating, ventilating and air
conditioning ducting to loading effects caused by natural phenomena, such as tornados.
Specifically, while performing a review in response to an NRC generic communication,
the licensee determined that they could not demonstrate the ability of the stations
emergency diesel generators heating, ventilating and air conditioning ducting to
withstand a tornado depressurization event. However no actions were taken to correct
or mitigate this issue at the time of discovery.
Description. On December 6, 2006, the NRC issued Regulatory Issue
Summary 2006-23, Post-Tornado Operability of Ventilating and Air-conditioning
Systems Housed in Emergency Diesel Generator Rooms. The purpose of this
Regulatory Information Summary was to notify licensees of the NRCs regulatory
position regarding loading effects caused by natural phenomena on safety related
systems and components housed inside a structure partially exposed to the outside
environment. Specifically, ventilating and air conditioning systems housed in the
emergency diesel generator rooms. The NRC expects licensees to consider natural
hazards during the design of systems and components housed inside safety-related
structures if these systems and components may be exposed to the outside environment
and if their malfunction or loss may prevent or impact the operability of safety-related
systems and components.
Of particular concern was that vented ventilating and air conditioning ducts, and other
internal safety-related systems and components, may be subject to the effects of rapid
room depressurization and re-pressurization and other effects associated with a tornado
event. In some cases the loss of structural integrity of ventilating and air conditioning
systems may pose a challenge to the safe operation of the facility. In such cases,
- 21 -
Enclosure 2
licensees should take necessary measures to ensure the operability of ventilating and air
conditioning duct systems located in emergency diesel generator rooms.
On December 6, 2006, Entergy corporate initiated Condition Report LO-LAR-2006-0171
to have all sites perform a review of Regulatory Information Summary 2006-023.
Specifically, each site was to determine if the site's design had adequately considered
tornado wind and pressure drop effects on safety-related systems and components
inside building structures open to the outside environment.
On April 12, 2007, the licensee completed their review and concluded that the plant's
design criteria to comply with General Design Criteria GDC-2 requires that the structure
remain fully functional before, during, and after a tornado event without exceeding ASME
Code allowables. The original designers accomplished this by: (1) designing the
external structure (walls, ceilings, floors) to resist tornado winds, missiles, and
depressurization; and (2) providing missile barriers near openings into the building
where a missile trajectory could potentially directly strike a safety-related
system/component. The temporary effects associated with a rapid external
depressurization of systems and components were not considered in the original
analyses. The safety-related components of Arkansas Nuclear Ones heating,
ventilation, and air conditioning system are protected from tornados and other natural
events by being located within the protection of reinforced concrete structures.
Arkansas Nuclear Ones reinforced concrete structures that house safety-related
equipment are designed to resist the effects of tornado conditions. For these structures,
the ventilation system intakes and exhausts are designed to resist tornado generated
missiles. However, neither the design basis nor the licensing basis required ventilation
systems to be designed for the differential pressures associated with a tornado. Units 1
and 2 were licensed before the issuance of Regulatory Guide 1.76 and are not
committed to it.
Based on interactions with the Entergy fleet, the licensee subsequently determined that
it would be prudent to further evaluate the tornado depressurization event and its
potential impact on the diesel generator rooms ventilation systems. The licensee
initiated Condition Report CR-ANO-C-2007-1308 to facilitate this. The licensee
performed subsequent calculations, based upon sound engineering principles using the
reduced differential pressures noted in Regulatory Guide 1.76, Revision 1, to evaluate
the emergency diesel generator ductwork and emergency diesel generator inlet dampers
in both units for effects of a tornado depressurization event. These calculations
concluded that; for Unit 2, initially closed emergency diesel generator inlet dampers
would be rendered inoperable by the event and resulting deformations would prevent
subsequent automatic opening; and for Unit 1, the emergency diesel generator inlet
ductwork to the combustion air filters would collapse and cut off air flow to the engines.
They also indicated that the suction ductwork to the exhaust fans in both units would
collapse and cut off air flow to the exhaust fans. Based on these results, station design
engineering could not ensure with a high level of confidence that the emergency diesel
generator combustion air and ventilation systems would remain functional after a
tornado event.
- 22 -
Enclosure 2
The inspectors reviewed this position and associated calculations and determined that
this was contrary to the regulatory position taken by the NRC in Regulatory Issue
Summary 2006-023. The inspectors also noted; that the licensee had evaluated piping
systems not located in Class 1 structures for tornado induced pressure differentials in
their Final Safety Analysis Report, and that the licensee had used differential pressures
which were less than those specified in their licensing basis to perform their evaluations.
As such, the inspectors questioned the diesel generator rooms ventilation system
capabilities to withstanding the rapid depressurization effects that can occur coincident
with a tornado. Specifically, the inspectors concluded that the evaluations that had been
performed to date did not provide a reasonable expectation of operability for the diesel
generator rooms ventilation systems in a tornado event, and the licensee had taken no
actions to provide compensatory measures to ensure continued operability.
The inspectors presented their concerns to the licensee and the licensee determined
that further review was necessary to determine the acceptability of the identified issues.
The licensee initiated Condition Report CR-ANO-C-2009-2296 to address these
concerns. Subsequent evaluations determined that the Unit 2 emergency diesel
generator ventilating and air conditioning systems would be able to withstand a tornado
event; but Unit 1 required compensatory measures to demonstrate operability for a
design basis tornado event.
Analysis. The failure to promptly identify and correct a know condition adverse to quality
associated with the susceptibility of the Unit 1 emergency diesel generators' heating,
ventilating and air conditioning ducting to loading effects caused by natural phenomena,
tornados, was a performance deficiency. The performance deficiency was determined
to be more than minor because it was associated with the protection against external
events attribute of the Mitigating Systems Cornerstone, and affected the associated
cornerstone objective to ensure the availability, reliability, and capability of systems that
respond to initiating events to prevent undesirable consequences, and is therefore a
finding. Using Manual Chapter 0609.04, Phase 1 - Initial Screening and
Characterization of Findings, the finding was determined to have very low safety
significance because the finding: (1) was not a design or qualification issue confirmed
not to result in a loss of operability or functionality; (2) did not represent an actual loss of
safety function of the system or train; (3) did not result in the loss of one or more trains of
nontechnical specification equipment; and (4) did not screen as potentially risk
significant due to a seismic, flooding, or severe weather initiating event. The finding was
determined to have a crosscutting aspect in the area of human performance, associated
with decision making, H.1(b), in that the licensee failed to use conservative assumptions
in decision making and adopt a requirement to demonstrate that the proposed action is
safe in order to proceed rather than a requirement to determine it is unsafe in order to
disapprove the action.
Enforcement. Title 10 of the Code of Federal Regulations Part 50, Appendix B,
Criterion XVI, Corrective Action, requires, in part, that Measures shall be established
to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies,
deviations, defective material and equipment, and nonconformances are promptly
identified and corrected. Contrary to the above, from December 2006 through
- 23 -
Enclosure 2
November 2009, the licensee failed to ensure that a known condition adverse to quality
associated with the susceptibility of the Unit 1 emergency diesel generators' heating,
ventilating and air conditioning ducting to loading effects caused by natural phenomena,
tornados, was corrected in a timely manner. Because this finding is of very low safety
significance and has been entered into the corrective action program as Condition
Report CR-ANO-C-2009-2296, this violation is being treated as a noncited violation
consistent with Section 2.3.2.a of the NRC Enforcement Policy: NCV 05000313/2010004-02, Failure to Promptly Identify and Correct a Condition Adverse to
Quality Associated with Emergency Diesel Generator Heating, Ventilation and Air
Conditioning Ducting Susceptibility to Tornado Loading.
1R18 Plant Modifications (71111.18)
Permanent Plant Modifications
a.
Inspection Scope
The inspectors reviewed key affected parameters associated with energy needs,
materials/replacement components, timing, heat removal, control signals, equipment
protection from hazards, operations, flow paths, pressure boundary, ventilation
boundary, structural, process medium properties, licensing basis, and failure modes for
the modification listed below.
Unit 1, modifications performed to emergency switchgear chillers VCH-4A/B
The inspectors verified that modification preparation, staging, and implementation did
not impair emergency/abnormal operating procedure actions, key safety functions, or
operator response to loss of key safety functions; postmodification testing will maintain
the plant in a safe configuration during testing by verifying that unintended system
interactions will not occur, systems, structures and components performance
characteristics still meet the design basis, the appropriateness of modification design
assumptions, and the modification test acceptance criteria will be met; and licensee
personnel identified and implemented appropriate corrective actions associated with
permanent plant modifications. Specific documents reviewed during this inspection are
listed in the attachment.
These activities constitute completion of one (1) sample for permanent plant
modifications as defined in Inspection Procedure 71111.18-05
a.
Findings
Introduction. The inspectors documented a Green self-revealing noncited violation of
10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the failure of the
licensee to promptly identify and correct a known condition adverse to quality associated
with the improper setup of the dead band of service water flow control valve CV-6034 for
cold weather operation. This resulted in the pressure control valve not properly
modulating in response to pressure control inputs and the chiller tripping on high
discharge pressure.
- 24 -
Enclosure 2
Description. On December 1, 2009, the licensee was conducting a normal surveillance
run of emergency switchgear chiller VCH-4A in accordance with station
Procedure OP-1104.027, Battery and Switchgear Emergency Cooling System,
Revision 5. During this run, operators noted the discharge pressure for the chiller was
cycling excessively, followed by the chiller tripping on high discharge pressure. This
issue was entered into the stations corrective action program as Condition
Report CR-ANO-1-2009-2212.
The licensee performed an apparent cause evaluation of this issue as documented in
Condition Report CR-ANO-1-2009-2212. During their review, the licensee noted that a
similar issue had occurred previously on chiller VCH-4B in January 2008, and was
documented in Condition Report CR-ANO-1-2008-0098. The apparent cause of that
issue had been determined to be degraded and/or inappropriate set-up of the dead band
of the Modutronic circuit board for service water flow control valve CV-6036. This was
corrected by adjusting the gain so that the dead band was more appropriate, resulting in
less movement and no motor thermal overload concerns for cold weather operation.
The licensee also noted that the extent of condition review had identified CV-6034, the
service water flow control for VCH-4A, as being susceptible to this issue. However,
because a degraded piece/part had been discovered on CV-6036 (gain potentiometer
disengaged) and no previous issues had been identified with CV-6034, no corrective
actions were pursued to troubleshoot and repair CV-6034. Instead, the model work
order for these valves was revised to incorporate some lessons learned for future
maintenance.
The licensee determined that the apparent cause of the improper operation of the valves
was an increase in stroke times of the valves. Specifically, CV-6034 and CV-6036 valve
bodies were replaced in December 2006 with stainless steel bodies, where they formerly
utilized carbon steel bodies, and the subsequent testing performed indicated that the
opening stroke times had increased by as much as 20 percent with no changes to the
motor-operated valve dead band adjustment. The licensee determined that these motor
operated valves had very little margin regarding current draw and overload relay
settings, and this change introduced enough additional drag or load on the motor
operated valve that the overload relay settings trip during certain modes of operation.
This was corrected by adjusting the gain so that the dead band was more appropriate,
resulting in less movement and no motor thermal overload concerns for cold weather
operation.
Analysis. Failure to promptly identify and correct a known condition adverse to quality
associated with the improper setup of the dead band of service water flow control
valve CV-6034 for cold weather operation was a performance deficiency. The
performance deficiency was determined to be more than minor because it was
associated with the equipment performance attribute of the Mitigating Systems
Cornerstone, and affected the associated cornerstone objective to ensure the
availability, reliability, and capability of systems that respond to initiating events to
prevent undesirable consequences, and is therefore a finding. Using Manual
Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the
- 25 -
Enclosure 2
finding was determined to have very low safety significance because: (1) the finding
was not a qualification deficiency that resulted in a loss functionality of chiller VCH-4A;
(2) it did not lead to an actual loss of safety function of the system or train; (3) it did not
result in an actual loss of safety function of a single train for greater than its technical
specification allowed outage time; (4) it did not represent an actual loss of safety function
of one or more nontechnical specification trains of equipment designated as risk-
significant per 10 CFR 50.65, for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; (5) it did not screen as
potentially risk-significant due to a seismic, flooding, or severe weather initiating event.
The finding was determined to have a crosscutting aspect in the area of human
performance, associated with decision making in that, although the licensee had
identified the vulnerability of the VCH-4A chiller, decided not to pursue the corrective
actions to adjust the dead band for valve CV-6034 and resulted in the subsequent
improper operation of the valve H.1(b).
Enforcement. Title 10 of the Code of Federal Regulations Part 50, Appendix B,
Criterion XVI, Corrective Action, requires, in part, that Measures shall be established
to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies,
deviations, defective material and equipment, and nonconformances are promptly
identified and corrected. Contrary to the above, from December 2006 through
December 2009 the licensee failed to ensure that a known condition adverse to quality
associated with the setup of the dead band for service water flow control valve CV-6034,
which affected the operation of the valve during cold weather operations, was corrected
in a timely manner. Because this finding is of very low safety significance and has been
entered into the corrective action program as Condition Report CR-ANO-1-2009-2212,
this violation is being treated as a noncited violation consistent with Section 2.3.2.a of
the NRC Enforcement Policy: NCV 05000313/2010004-03, Failure to Promptly Identify
and Correct a Condition Adverse to Quality Associated with Emergency Switchgear
Chiller VCH-4A.
1R19 Postmaintenance Testing (71111.19)
a.
Inspection Scope
The inspectors reviewed the following postmaintenance activities to verify that
procedures and test activities were adequate to ensure system operability and functional
capability:
July 7, 2010, Unit 1, P-7A turbine driven emergency feedwater pump speed
circuit calibration after electronic governor module replacement
July 14, 2010, Unit 1, VCH-4B TS-6060 lockout on high temperature emergency
temporary modification and corrective maintenance
July 30, 2010, Unit 2, Alternate AC diesel generator after maintenance period
August 4-5, 2010, Unit 2, Containment spray transmitter 2FT-5610 following
replacement activities
- 26 -
Enclosure 2
August 22, 2010, Unit 2, Emergency diesel generator 2K-4B following repair
activities for a crank case vacuum issue
Week of Sept 6, 2010, Unit 2, Emergency diesel generator 2 following extensive
maintenance to resolve crankcase vacuum issue
The inspectors selected these activities based upon the structure, system, or
component's ability to affect risk. The inspectors evaluated these activities for the
following:
The effect of testing on the plant had been adequately addressed; testing was
adequate for the maintenance performed
Acceptance criteria were clear and demonstrated operational readiness; test
instrumentation was appropriate
The inspectors evaluated the activities against the technical specifications, the Safety
Analysis Report, 10 CFR Part 50 requirements, licensee procedures, and various NRC
generic communications to ensure that the test results adequately ensured that the
equipment met the licensing basis and design requirements. In addition, the inspectors
reviewed corrective action documents associated with postmaintenance tests to
determine whether the licensee was identifying problems and entering them in the
corrective action program and that the problems were being corrected commensurate
with their importance to safety. Specific documents reviewed during this inspection are
listed in the attachment.
These activities constitute completion six (6) postmaintenance testing inspection
samples as defined in Inspection Procedure 71111.19-05.
b.
Findings
Introduction. The inspectors documented a self-revealing finding for station electrical
maintenance personnel's failure to adequately implement station Procedure EN-WM-
102, Work Implementation and Closeout, Revision 4. Specifically, station personnel
performing Work Order 00182908-01, removal/reinstallation of isophase fan motor C-8A,
did not stop work when a condition that was not identified in the work order was
discovered.
Description. On March 24, 2010, during Refueling Outage 1R22, maintenance
personnel performed work on the Unit 1 isophase blower fan motor C-8A using station
Work Order 00182908-01. The purpose of the work order was to remove the fan motor
for rewinding off site and reinstallation. During de-termination of the fan motor power
leads, two additional leads were removed from two of the three phases and documented
on the lifted lead log sheet. After the motors return to the site, on April 7-8, 2010, the
original lifted lead log was used to re-terminate the motor heater leads, vibration probes,
and grounds. A new lifted lead log was prepared to re-terminate the motor leads since
they had been relabeled. Two wires that were not labeled or lugged were identified and
the maintenance personnel assumed that they were spares and were left as found.
- 27 -
Enclosure 2
Motor rotation was checked and the work was completed. Following completion of the
refueling outage, on April 27, 2010, while operators were attempting to swap isophase
fans, it was discovered that the damper for isophase blower C-8A failed to open. This
was documented in Condition Report CR-ANO-1-2010-2105. Subsequently, station
Work Order 00235005 was generated to troubleshoot why the damper did not open.
Work was completed on May 11, 2010. Subsequently, maintenance initiated Condition
Report CR-ANO-1-2010-2260 which identified that, following the troubleshooting, the
power supply leads for the damper motors were not terminated in the fan motor
termination box.
The licensee performed an apparent cause evaluation of the issue, documented in
Condition Report CR-ANO-1-2010-2260, and during the inspectors' review, they noted
the maintenance personnel did not question the removal of two power leads from two of
the motor phases and only one power lead for the other motor phase and continued the
work and did not communicate the discrepancy for a potential scope change to the work
order. The inspectors determined this to be contrary to Station Procedure EN-WM-102,
Work Implementation and Closeout, Revision 4, which states, in part, in Section 5.3
that a scope change has occurred if any of the following are identified during
performance of the work: The activity is not covered by the postmaintenance test; the
work instructions require a revision other than an editorial change, detail classification,
enhancement, or remedy of omissions; or additional components or systems are
affected. As such, the inspectors determined that maintenance personnel had failed to
follow station procedure and generate a scope change to the work package.
Analysis. Failure of station maintenance personnel to follow the requirements of station
Procedure EN-WM-102 and process a scope change due to unexpected conditions for
this reference level work package was a performance deficiency. The finding was more
than minor because it affected the human performance attribute of the Initiating Events
Cornerstone, and it directly affected the cornerstone objective to limit the likelihood of
those events that upset plant stability during power operations. Using Manual
Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the
finding was determined to have very low safety significance because it did not contribute
to both the likelihood of a reactor trip and the likelihood that mitigation equipment or
functions would not be available. The finding had a crosscutting aspect in the area of
Human Performance associated with work practices H.4(a), in that the licensee failed
to communicate human error prevention techniques, such as holding pre-job briefings,
self- and peer-checking, and proper documentation of activities. Specifically, station
maintenance personnel failed to follow Procedure EN-WM-102 when discovering a
condition that was unexpected for this work package and did not stop work to resolve the
issue prior to continuing with the work which resulted in inadequate completion and
testing in the work package for the planned activities for the isophase blower motor and
Enforcement. This finding does not involve enforcement action because no regulatory
requirement violation was identified, since the affected isophase blower damper is not
safety-related. Because this finding does not involve a violation, has very low safety
significance, and has been entered into the corrective action program as
- 28 -
Enclosure 2
Condition Report CR-ANO-1-2010-2260, it is identified as FIN 05000313/2010004-04,
Failure to Follow Station Work Control Procedure Results in Unavailable Equipment.
1R20 Refueling and Other Outage Activities (71111.20)
a.
Inspection Scope
The inspectors reviewed the outage plan and contingency plans for the Unit 2 Forced
Outage 2FO1 conducted August 23 through September 4, 2010, to confirm that licensee
personnel had appropriately considered risk, industry experience, and previous site-
specific problems in developing and implementing a plan that assured maintenance of
defense in depth. During the forced outage, the inspectors observed portions of the
shutdown and cooldown processes and monitored licensee controls over the outage
activities listed below.
Configuration management, including maintenance of defense in depth, is
commensurate with the outage safety plan for key safety functions and
compliance with the applicable technical specifications when taking equipment
out of service
Installation and configuration of reactor coolant pressure, level, and temperature
instruments to provide accurate indication, accounting for instrument error
Status and configuration of electrical systems to ensure that technical
specifications and outage safety plan requirements were met and controls over
switchyard activities
Monitoring of decay heat removal processes, systems, and components
Controls over activities that could affect reactivity
Startup and ascension to full power operation, tracking of startup prerequisites,
walkdown of the primary containment to verify that debris had not been left which
could block emergency core cooling system suction strainers, and reactor
physics testing
Licensee identification and resolution of problems related to forced outage
activities
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one (1) forced outage inspection sample as
defined in Inspection Procedure 71111.20-05.
b.
Findings
Introduction. The inspectors identified a Green cited violation of 10 CFR Part 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the
- 29 -
Enclosure 2
licensees failure to adequately implement Procedure EN-MA-118, Foreign Material
Exclusion, Revision 5/6. Specifically, between October 31, 2008, and September 2,
2010, inspectors identified multiple occasions where licensee personnel failed to
implement appropriate foreign material exclusion controls in Zone 1 areas around safety-
related equipment (e.g. failure to appropriately log material in to and out of the zone) as
required by station procedure. Each identified instance was a repeat occurrence of
previously identified issues that were documented as NRC identified violations in
previous inspection reports in 2008, 2009, and early 2010. Measures established by
Arkansas Nuclear One to address these previously identified noncited violations failed to
restore compliance within a reasonable time after these violations were identified.
Finally, these failures had the potential of having a negative impact on safety related
components such as fuel failure, safety system reliability and safety related equipment
availability. This issue was entered into the licensee's corrective action program as
Condition Reports CR-ANO-2-2010-1839, CR-ANO-C-2010-2192, and
CR-ANO-X-2010-3155.
Description. Inspectors issued NCVs05000313/2008005-03, 05000368/2009004-04,
and 05000313/2010003-02 to the licensee for the failure of licensee personnel to
appropriately implement the requirements of station procedure EN-MA-118, for foreign
material exclusion controls in areas designated as Zone 1 foreign material exclusion
areas.
05000313/2008005-03: The resident staff identified multiple issues with the
licensees implementation of their foreign material control program during
refueling outage 1R21. Specifically, the resident staff determined that the issue
was associated with the failure of station personnel to follow the procedural
requirements including failure to adequately log materials in to and out of a Zone
1 area. (Note: while there were multiple examples identified of station
personnels failure to follow procedure, there were no actual introductions of
material into critical systems).
The licensee performed an apparent cause evaluation and determined the
apparent cause was poor worker and supervisory work practices. Specifically,
supervision and management were lacking in oversight performance, which was
due to the significant procedure changes not being recognized as a potential trap
for those implementing the procedure from a worker / FME Monitor / supervisor
standpoint. Change management was inadequate from an oversight
perspective. The licensee also identified as a contributing cause inadequate
training / procedure knowledge for supervisor and craft.
05000368/2009004-04: The resident staff identified multiple issues with the
licensees implementation of their foreign material control program during
refueling outage 2R20. The resident staff determined that the issue was
associated with the failure of station personnel to follow the procedural
requirements including failure to adequately log material in to and out of a Zone 1
area. (Note: this was after the completion of all corrective actions for NCV 05000313/2008005-03). Additionally, some of these examples included actual
- 30 -
Enclosure 2
introductions of material into critical systems that had not been logged when
taken into the Zone 1 area.
The licensee performed an apparent cause evaluation and determined there to
be two apparent causes; proper worker practices have not been reinforced
through supervisor feedback (AC1) and in training (AC2). (The residents noted
that these were essentially the same causes that had been identified previously;
apparent cause was poor worker and supervisory work practices, and the
contributing cause inadequate training / procedure knowledge for supervisor and
craft.)
05000313/2010003-02: The resident staff identified multiple issues with the
licensees implementation of their foreign material control program during
refueling outage 1R22. The resident staff determined that the issue was
associated with the failure of station personnel to follow the procedural
requirements. (Note: this was after the completion of all corrective actions for the
previous NCVs05000313/2008005-03 and 05000368/2009004-04, and some of
these examples were actual introductions of material into critical systems)
The licensee did not perform an apparent cause evaluation for this issue.
Instead, each issue was addressed in the condition report that identified it, and a
rollup condition report was written to capture lessons learned for future refueling
outages.
The inspectors noted that the condition reports that captured the individual issues
actually failed to appropriately call out the failure to follow procedure. Instead,
most were closed to actions taken for material recovery, and/or coaching.
On August 24, 2010, while conducting a tour of the facility the inspectors noted work in
progress in the area of the safety related emergency diesel generator 2K-4B, which had
been designated a Zone 1 foreign material exclusion area, was not in accordance with
station procedures. Specifically, the inspectors noted that individuals working in the area
were not appropriately implementing the requirements of station Procedure EN-MA-118,
Foreign Material Exclusion, Revision 5. The inspectors identified that some personnel
in the zone 1 foreign material exclusion area failed to have their hard hats, eye
protection, pens or tools properly secured. The inspectors informed the licensee of this
issue and it was entered into the corrective action program as Condition Report
CR-ANO-2-2010-1839.
On August 25, 2010, while touring emergency diesel generator 2K-4B room again, the
inspectors again identified issues with station personnels implementation of the
requirements of station procedure EN-MA-118 for a Zone 1 foreign material exclusion
area. Specifically, the inspectors identified that a clear plastic bag had been introduced
into the Zone 1 foreign material exclusion area (procedurally clear plastic is not allowed
in foreign material exclusion zone 1 areas without distinguishing markings) and this bag
had not been logged into the foreign material exclusion area log. The inspectors also
observed station personnel placing a spiral wound notebook and pen in the Zone 1
foreign material exclusion area without logging them in and verifying they were failsafe
- 31 -
Enclosure 2
as required by procedure. The inspectors informed the licensee of this issue and it was
entered into the corrective action program as Condition Report CR-ANO-C-2010-2192.
On September 2, 2010, while touring the spent fuel floor, the inspectors again identified
issues with station personnels implementation of the requirements of station procedure
EN-MA-118 for a Zone 1 foreign material exclusion area. Specifically, the inspectors
observed an individual enter the Zone 1 area around the spent fuel pool for Unit 1,
without their hard hat being properly secured. The inspectors determined that this
represented an instance where foreign material, the hard hat, could be introduced into a
safety related system containing spent fuel assemblies. The inspectors informed the
licensee of this issue and it was entered into the corrective action program as Condition
Report CR-ANO-1-2010-3155.
Through their review the inspectors determined that the licensee had failed to ensure
that Procedure EN-MA-118 requirements were followed. Specifically, the station
personnel failed to appropriately secure material entering a Zone 1 foreign material
exclusion area and failed to properly log material entering a Zone 1 foreign material
exclusion area to ensure accountability was maintained. The inspectors also determined
that there has been sufficient time for previous corrective actions identified by the
licensee to take effect, and as such, the previous corrective actions that had been taken
were inadequate.
The inspectors concluded that while the identified examples of station personnels failure
to follow Procedure EN-MA-118 was indicative of a continued programmatic issue
associated with the station personnels implementation of the foreign material exclusion
program which could directly impact safety related equipment as well as critical systems.
While there was no actual damage to station critical systems, there has been at least
one example of introduction of foreign material into a critical system, which was
discovered before damage occurred.
Analysis. The failure of station personnel to follow Procedure EN-MA-118, Foreign
Material Exclusion, when working in Zone 1 foreign material exclusion areas around
safety related equipment/areas, was a performance deficiency. The performance
deficiency was determined to be more than minor because it was associated with the
human performance attribute of the Mitigating Systems Cornerstone, and affected the
associated cornerstone objective to ensure the availability, reliability, and capability of
systems that respond to initiating events to prevent undesirable consequences, and is
therefore a finding. Using the Manual Chapter 0609, Significance Determination
Process, Phase 1 Worksheets, the finding was determined to have very low safety
significance because the finding: (1) was not a design or qualification issue confirmed
not to result in a loss of operability or functionality; (2) did not represent an actual loss of
safety function of the system or train; (3) did not result in the loss of one or more trains of
nontechnical specification equipment; and (4) did not screen as potentially risk
significant due to a seismic, flooding, or severe weather initiating event. The finding was
determined to have a crosscutting aspect in the area of problem identification and
resolution, associated with the corrective action program, P.1(d), in that the licensee
takes appropriate corrective actions to address safety issues and adverse trends in a
timely manner, commensurate with their safety significance and complexity.
- 32 -
Enclosure 2
Enforcement. Title 10 of the Code of Federal Regulations Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities
affecting quality shall be prescribed by documented instructions, procedures or
drawings, of a type appropriate to the circumstances and shall be accomplished in
accordance with these instructions, procedures, or drawings.
Arkansas Nuclear One Procedure EN-MA-118, Foreign Material Exclusion, Revision 6
requires the establishment of a Foreign Material Exclusion Zone 1 when loss of foreign
material exclusion integrity could result in fuel failure, reduced system safety, station
availability or significant cost for recovery. Section 5.11, FME Zone 1 Requirements, of
the same procedure, states in part that for Foreign Material Exclusion Zone 1, the
Foreign Material Exclusion Monitor shall control personnel and material access to the
Foreign Material Exclusion zone.
Contrary to the above, between October 31, 2008, and September 2, 2010, Arkansas
Nuclear One failed to ensure Foreign Material was controlled in accordance with the
requirements of Procedure EN-MA-118. Specifically, the inspectors identified multiple
occasions where the licensee personnel failed to implement appropriate foreign material
exclusion controls (e.g., failure to appropriately log material in to and out of the area) in
Foreign Material Exclusion Zone 1 areas around safety-related equipment as required by
station procedure. Additionally, these failures had the potential of having a negative
impact on safety-related components.
This finding was of very low safety significance and was entered into the licensees
corrective action program as condition reports CR-ANO-2-2010-1839,
CR-ANO-C-2010-2192, and CR-ANO-1-2010-3155. Due to the described programmatic
nature, this violation is being cited in a Notice of Violation consistent with Section 2.3.2.a
of the NRC Enforcement Policy: VIO 05000313;05000368/2010004-05, Failure to
Adequately Implement Foreign Material Exclusion Controls.
1R22 Surveillance Testing (71111.22)
a.
Inspection Scope
The inspectors reviewed the Safety Analysis Report, procedure requirements, and
technical specifications to ensure that the surveillance activities listed below
demonstrated that the systems, structures, and/or components tested were capable of
performing their intended safety functions. The inspectors either witnessed or reviewed
test data to verify that the significant surveillance test attributes were adequate to
address the following:
Preconditioning
Evaluation of testing impact on the plant
Acceptance criteria
- 33 -
Enclosure 2
Test equipment
Procedures
Test data
Testing frequency and method demonstrated technical specification operability
Test equipment removal
Restoration of plant systems
Fulfillment of ASME Code requirements
Updating of performance indicator data
Engineering evaluations, root causes, and bases for returning tested systems,
structures, and components not meeting the test acceptance criteria were correct
Reference setting data
Annunciators and alarms setpoints
The inspectors also verified that licensee personnel identified and implemented any
needed corrective actions associated with the surveillance testing.
July 7, 2010, Unit 2, Emergency diesel generator 1 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> endurance run
July 9, 2010, Unit 2, Emergency diesel generator 2 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> endurance run
July 14, 2010, Unit 1 , VCH-4B, Emergency switchgear chiller quarterly
surveillance test
August 4-5, 2010, Unit 2, Containment spray pump train A
August 22, 2010, Unit 2, Emergency feedwater pump 2P-7A
August 23, 2010, Unit 1, P-7A, Turbine-driven emergency feedwater pump
quarterly surveillance test
September 2, 2010, Unit 2, Emergency diesel generator 2 after forced
maintenance outage activities
September 28-30, 2010, Unit 1 and Unit 2, Reactor coolant system leakage
calculations
September 30, 2010, Unit 1, Containment isolation valve SV-1818, pressurizer
sampling and reactor coolant system sampling isolation valve
- 34 -
Enclosure 2
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of nine (9) surveillance testing inspection samples
as defined in Inspection Procedure 71111.22-05.
b.
Findings
Introduction. The inspectors documented a Green self-revealing noncited violation of
10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the
licensees failure to assure that the applicable design basis for applicable structures,
systems, and components were correctly translated into specifications, procedures, and
instructions. Specifically, during initial plant installation the licensee failed to correctly
identify the effect redundant protective equipment interlocks could have on maintaining
operability of VCH-4B design requirements upon a loss of normal non-safety cooling.
This resulted in emergency switchgear chiller VCH 4B, not being able to start and
perform its design function due to a combination of high room temperature due to loss of
normal non-safety related cooling and normally energized compressor oil heaters which
led to a high compressor oil temperature switch actuation that caused a lockout of the
chiller that would have prevented a chiller start.
Description. At 2:10 p.m. on July 14, 2010, the Unit 1 control room received a
VCH-4A/B trouble alarm. Local investigation found the high oil temperature/high
discharge pressure alarm/lockout was active on south emergency switchgear
chiller VCH-4B. Chiller VCH-4B was and had been idle prior to the receipt of the control
room alarm. Subsequent investigation determined that high oil temperature
switch TS-6060 for chiller VCH-4B, had actuated on a valid high oil temperature
condition in compressor C-52, for chiller VCH-4B.
Normal nonsafety-related room cooler VUC-2A, for room 100 where chiller VCH-4B is
located, had failed some time during the day and had caused the temperature in
room 100 to rise. Chiller VCH-4B compressor C-52 is designed with a compressor sump
oil heater element that is energized when the unit is offline to avoid refrigerant emulsion
into the oil. The combined effect of the loss of normal room cooling, the energized oil
heaters, and the high ambient temperature led to oil sump temperatures reaching the
actuation set point of 157 degrees Fahrenheit for TS-6060, causing a lockout of
chiller VCH-4B.
The licensee declared chiller VCH-4B inoperable at 2:38 p.m. and commenced
performing contingency actions contained in Procedure OP-1104.027, Battery and
Switchgear Emergency Cooling System, to exit the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> allowed outage time of
Technical Specifications 3.8.4, 3.8.9, and the 12 shutdown action statements for
Technical Specification 3.8.7, and to then enter a 30 day administrative time clock.
However, one of the required nonsafety-related coolers, VUC-13B, north battery charger
normal cooling, was out of service for maintenance. This prevented the completion of
the contingency actions of Procedure OP-1104.027 and kept the station in a limiting
12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shutdown action statement of Technical Specification 3.8.7. At 9:58 p.m., Unit 1
exited all technical specification limiting condition for operations when VCH-4B was
declared operable after implementation of an emergency temporary modification, an
- 35 -
Enclosure 2
engineering evaluation to permanently disable hi compressor oil temperature
lockout TS-6060 and performing the monthly surveillance test to demonstrate equipment
operability. The licensee initiated Condition Report CR-ANO-1-2010-2815 to document
the issue in the stations corrective action program. The licensee documented the
operability of north emergency switchgear chiller VCH-4A, in Condition
Report CR-ANO-1-2010-3075. The licensee performed an apparent cause evaluation
and developed a corrective action plan to permanently disable the compressor sump
high oil temperature lockout feature for both chillers VCH-4B and VCH-4A.
Analysis. The inspectors determined that the licensees failure to ensure that design
requirements were correctly translated into installed plant equipment was a performance
deficiency. The performance deficiency was determined to be more than minor because
it was associated with the equipment performance attribute of the Mitigating Systems
Cornerstone and affected the associated cornerstone objective to ensure availability,
reliability, and capability of systems that respond to initiating events to prevent
undesirable consequences, and is therefore a finding. Specifically, the licensee failed to
correctly analyze and identify that chiller VCH-4B could receive a high oil temperature
lockout with a loss of normal room cooling prior to receiving a valid start signal due to the
compressor sump oil heaters and a high ambient room temperature and prevent
fulfillment of its required design function. Using Manual Chapter 0609.04, Phase 1 -
Initial Screening and Characterization of Findings, the finding was determined to have
very low safety significance because: (1) the finding was not a qualification deficiency
that resulted in a loss of functionality of chiller VCH-4B; (2) it did not lead to an actual
loss of safety function of the system or train; (3) it did not result in an actual loss of
safety function of a single train for greater than its technical specification allowed outage
time; (4) it did not represent an actual loss of safety function of one or more non-
technical specification trains of equipment designated as risk-significant per
10 CFR 50.65, for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; (5) it did not screen as potentially risk-
significant due to a seismic, flooding, or severe weather initiating event. The inspectors
determined that since the licensee had not recently re-evaluated the design of the
emergency switchgear room chillers high oil temperature lockout; this finding did not
represent current plant performance, and therefore did not have a crosscutting aspect
associated with it
Enforcement. Title 10 of the Code of Federal Regulations Part 50, Appendix B,
Criterion III, Design Control, requires, in part, measures be established to assure that
applicable regulatory requirements and the design basis, as defined in 10 CFR 50.2 and
as specified in the license application, for those components to which this appendix
applies are correctly translated into specifications, drawings, procedures, and
instructions. Contrary to the above, from initial installation through July 2010, the
licensee failed to ensure that that design requirements for the Unit 1 emergency
switchgear chillers were correctly translated into installed plant equipment. Because this
finding is of very low safety significance and has been entered into the corrective action
program as Condition Report CR-ANO-1-2010-2815, this violation is being treated as a
noncited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy:
NCV 05000313/2010004-06, Failure to Correctly Translate VCH-4B Design
Requirements into Installed Plant Configuration.
- 36 -
Enclosure 2
2.
RADIATION SAFETY
Cornerstone: Occupational and Public Radiation Safety
2RS06 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)
a.
Inspection Scope
This area was inspected to: (1) ensure the gaseous and liquid effluent processing
systems are maintained so radiological discharges are properly mitigated, monitored,
and evaluated with respect to public exposure; (2) ensure abnormal radioactive gaseous
or liquid discharges and conditions, when effluent radiation monitors are out of service,
are controlled in accordance with the applicable regulatory requirements and licensee
procedures; (3) verify the licensee=s quality control program ensures the radioactive
effluent sampling and analysis requirements are satisfied so discharges of radioactive
materials are adequately quantified and evaluated; and (4) verify the adequacy of public
dose projections resulting from radioactive effluent discharges. The inspectors used the
requirements in 10 CFR Part 20; 10 CFR Part 50, Appendices A and I; 40 CFR Part 190,
the offsite dose calculation manual, and licensee procedures required by the technical
specifications as criteria for determining compliance. The inspectors interviewed
licensee personnel and reviewed and/or observed the following items:
Radiological effluent release reports since the previous inspection and reports
related to the effluent program issued since the previous inspection, if any
Effluent program implementing procedures, including sampling, monitor setpoint
determinations and dose calculations
Equipment configuration and flow paths of selected gaseous and liquid
discharge system components, filtered ventilation system material condition,
and significant changes to their effluent release points, if any, and associated
10 CFR 50.59 reviews
Selected portions of the routine processing and discharge of radioactive gaseous
and liquid effluents (including sample collection and analysis)
Controls used to ensure representative sampling and appropriate compensatory
sampling
Results of the inter-laboratory comparison program
Effluent stack flow rates
Surveillance test results of technical specification-required ventilation effluent
discharge systems since the previous inspection
Significant changes in reported dose values, if any
- 37 -
Enclosure 2
A selection of radioactive liquid and gaseous waste discharge permits
Part 61 analyses and methods used to determine which isotopes are included in
the source term
Offsite dose calculation manual changes, if any
Meteorological dispersion and deposition factors
Latest land use census
Records of abnormal gaseous or liquid tank discharges, if any
Groundwater monitoring results
Changes to the licensees written program for indentifying and controlling
contaminated spills/leaks to groundwater, if any
Identified leakage or spill events and entries made into 10 CFR 50.75 (g)
records, if any, and associated evaluations of the extent of the contamination and
the radiological source term
Offsite notifications and reports of events associated with spills, leaks, or
groundwater monitoring results, if any
Audits, self-assessments, reports, and corrective action documents related to
radioactive gaseous and liquid effluent treatment since the last inspection
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of the one required sample, as defined in
Inspection Procedure 71124.06-05.
b.
Findings
No findings were identified.
2RS07 Radiological Environmental Monitoring Program (71124.07)
a.
Inspection Scope
This area was inspected to: (1) ensure that the radiological environmental monitoring
program verifies the impact of radioactive effluent releases to the environment and
sufficiently validates the integrity of the radioactive gaseous and liquid effluent release
program; (2) verify that the radiological environmental monitoring program is
implemented consistent with the licensees technical specifications and/or offsite dose
calculation manual, and to validate that the radioactive effluent release program meets
the design objective contained in Appendix I to 10 CFR Part 50; and (3) ensure that the
radiological environmental monitoring program monitors non-effluent exposure
- 38 -
Enclosure 2
pathways, is based on sound principles and assumptions, and validates that doses to
members of the public are within the dose limits of 10 CFR Part 20 and 40 CFR
Part 190, as applicable. The inspectors reviewed and/or observed the following items:
$
Annual environmental monitoring reports and offsite dose calculation manual
$
Selected air sampling and thermoluminescence dosimeter monitoring stations
$
Collection and preparation of environmental samples
$
Operability, calibration, and maintenance of meteorological instruments
$
Selected events documented in the annual environmental monitoring report
which involved a missed sample, inoperable sampler, lost thermoluminescence
dosimeter, or anomalous measurement
$
Selected structures, systems, or components that may contain licensed material
and has a credible mechanism for licensed material to reach groundwater
$
Records required by 10 CFR 50.75(g)
$
Significant changes made by the licensee to the offsite dose calculation manual
as the result of changes to the land census or sampler station modifications since
the last inspection
$
Calibration and maintenance records for selected air samplers, composite water
samplers, and environmental sample radiation measurement instrumentation
$
Inter-laboratory comparison program results
$
Audits, self-assessments, reports, and corrective action documents related to the
radiological environmental monitoring program since the last inspection
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of the one required sample as defined in
Inspection Procedure 71124.07-05.
b.
Findings
No findings were identified.
2RS08 Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage,
and Transportation (71124.08)
a.
Inspection Scope
This area was inspected to verify the effectiveness of the licensee=s programs for
processing, handling, storage, and transportation of radioactive material. The inspectors
used the requirements of 10 CFR Parts 20, 61, and 71 and Department of
- 39 -
Enclosure 2
Transportation regulations contained in 49 CFR Parts 171-180 for determining
compliance. The inspectors interviewed licensee personnel and reviewed the following
items:
$
The solid radioactive waste system description, process control program, and the
scope of the licensee=s audit program
$
Control of radioactive waste storage areas including container labeling/marking
and monitoring containers for deformation or signs of waste decomposition
$
Changes to the liquid and solid waste processing system configuration including
a review of waste processing equipment that is not operational or abandoned in
place
$
Radio-chemical sample analysis results for radioactive waste streams and use of
scaling factors and calculations to account for difficult-to-measure radionuclides
$
Processes for waste classification including use of scaling factors and
10 CFR Part 61 analysis
$
Shipment packaging, surveying, labeling, marking, placarding, vehicle checking,
driver instructing, and preparation of the disposal manifest
Audits, self assessments, reports, and corrective action reports radioactive solid
waste processing, and radioactive material handling, storage, and transportation
performed since the last inspection
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of the one required sample as defined in
Inspection Procedure 71124.08-05.
b.
Findings
Introduction. The inspectors identified a Green noncited violation of 10 CFR 20.2006(b)
for failure to ship radioactive waste with an accurate manifest.
Description. On May 19, 2009, the licensee shipped 20 Unit 2 spent fuel pool filters to a
waste processor for segregation. The waste manifest (NRC Forms 540 and 541)
accompanying the shipment indicated a total activity of 1650 millicuries based on dose
rate measurements of the filters. The recipient of the shipment performed dose
measurements of the filters to determine which filters could be kept for processing. The
licensee was notified on June 1, 2009, that dose rate on one filter was almost twice the
licensee reported dose rate (38 rem/hr vice 20 rem/hr) which equated to a total activity of
5000 millicuries. This event was documented in the corrective action program as
Condition Report CR-ANO-C-2009-1008. The licensee determined that the waste
classification of the shipment was unchanged by the higher curie content.
- 40 -
Enclosure 2
The total activity of the shipment based on the higher dose rate was approximately three
times more than reported on the shipping manifest. Until questioned by the inspectors,
the licensee failed to issue a corrected manifest or review how this event may have
affected other areas of the radiation protection program, such as reports made detailing
the amount of radioactive waste shipped annually. This was documented in the
corrective action program as Condition Report CR-ANO-C-2010-1866.
Analysis. The failure to include the correct total radioactivity on a waste manifest is a
performance deficiency. The finding is greater than minor because it was associated
with the Public Radiation Safety Cornerstone attribute of program and process
(transportation program), and affected the cornerstone objective, in that, it provided
incorrect information as part of hazard communication which could increase public dose.
Using the public radiation safety significance determination process, the inspectors
determined the finding had very low safety significance because (1) radiation limits were
not exceeded, (2) there was no breach of a package during transit, (3) it did not involve a
certificate of compliance issue, (4) it was not a low level burial ground nonconformance,
and (5) it did not involve a failure to make notifications or provide emergency
information. This finding had a crosscutting aspect in the area of corrective action
program, low threshold, because the licensee did not set a low threshold for identifying
issues completely and accurately P.1(a).
Enforcement. Title 10 of the Code of Federal Regulations 20.2006(b) requires, Any
licensee shipping radioactive waste intended for ultimate disposal at a licensed land
disposal facility must document the information required on NRCs uniform low-level
radioactive waste manifest and transfer this recorded manifest information to the
intended consignee in accordance with Appendix G to 10 CFR Part 20. Appendix G,
Section I. B, requires, in part, that, The shipper of the radioactive waste shall provide
the following information regarding the waste shipment on the uniform manifest: The
total radionuclide activity in the shipment. Contrary to the above, on May 19, 2009, the
licensee failed to provide an accurate total radionuclide activity on the manifest with
Radioactive Waste Shipment 09-051. Specifically, the manifest incorrectly listed the
total amount of radioactivity in the shipment as 1650 millicuries instead of approximately
5000 millicuries. This violation was entered into the licensees corrective action program
as Condition Report CR-ANO-C-2010-1866. This issue is being treated as a noncited
violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy:
NCV 05000368/2010004-07, Failure to Provide an Accurate Shipping Manifest.
- 41 -
Enclosure 2
4.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
Preparedness, Public Radiation Safety, Occupational Radiation Safety, and
4OA2 Identification and Resolution of Problems (71152)
.1
Routine Review of Identification and Resolution of Problems
a.
Inspection Scope
As part of the various baseline inspection procedures discussed in previous sections of
this report, the inspectors routinely reviewed issues during baseline inspection activities
and plant status reviews to verify that they were being entered into the licensees
corrective action program at an appropriate threshold, that adequate attention was being
given to timely corrective actions, and that adverse trends were identified and
addressed. The inspectors reviewed attributes that included the complete and accurate
identification of the problem; the timely correction, commensurate with the safety
significance; the evaluation and disposition of performance issues, generic implications,
common causes, contributing factors, root causes, extent of condition reviews, and
previous occurrences reviews; and the classification, prioritization, focus, and timeliness
of corrective actions. Minor issues entered into the licensees corrective action program
because of the inspectors observations are included in the attached list of documents
reviewed.
These routine reviews for the identification and resolution of problems did not constitute
any additional inspection samples. Instead, by procedure, they were considered an
integral part of the inspections performed during the quarter and documented in
Section 1 of this report.
b.
Findings
No findings were identified.
.2
Daily Corrective Action Program Reviews
a.
Inspection Scope
In order to assist with the identification of repetitive equipment failures and specific
human performance issues for follow-up, the inspectors performed a daily screening of
items entered into the licensees corrective action program. The inspectors
accomplished this through review of the stations daily corrective action documents.
The inspectors performed these daily reviews as part of their daily plant status
monitoring activities and, as such, did not constitute any separate inspection samples.
- 42 -
Enclosure 2
b.
Findings
No findings were identified.
.3
Semi-Annual Trend Review
a.
Inspection Scope
The inspectors performed a review of the licensees corrective action program and
associated documents to identify trends that could indicate the existence of a more
significant safety issue. The inspectors focused their review on repetitive equipment
issues, but also considered the results of daily corrective action item screening
discussed in Section 4OA2.2, above, licensee trending efforts, and licensee human
performance results. The inspectors nominally considered the 6-month period of
January 2010 through August 2010, although some examples expanded beyond those
dates where the scope of the trend warranted.
The inspectors also included issues documented outside the normal corrective action
program in major equipment problem lists, repetitive and/or rework maintenance lists,
departmental problem/challenges lists, system health reports, quality assurance
audit/surveillance reports, self-assessment reports, and Maintenance Rule assessments.
The inspectors compared and contrasted their results with the results contained in the
licensees corrective action program trending reports. Corrective actions associated with
a sample of the issues identified in the licensees trending reports were reviewed for
adequacy.
These activities constitute completion of one (1) single semi-annual trend inspection
sample as defined in Inspection Procedure 71152-05.
b.
Findings
No findings were identified.
.4
Selected Issue Follow-up Inspections
a.
Inspection Scope
Based on previous observations and identified issues, the inspectors selected, for a
more in-depth review, the stations work order generation process as it related to
maintenance activities planned on safety-related equipment. The inspectors selected
this issue for review because of the past history of inadequate work orders for planned
maintenance activities associated with plant equipment. Furthermore, the inspectors
determined that the failure to appropriately plan, provide appropriate guidance or
conduct appropriate postmaintenance testing because of inadequate work orders could
significantly impact on station equipment and result in these systems not being able to
perform their design functions. The inspectors considered the following, as applicable,
during the review of the licensee's actions: (1) complete and accurate identification of
- 43 -
Enclosure 2
the problem in a timely manner; (2) evaluation and disposition of operability/reportability
issues; (3) consideration of extent of condition, generic implications, common cause, and
previous occurrences; (4) classification and prioritization of the resolution of the problem;
(5) identification of root and contributing causes of the problem; (6) identification of
corrective actions; and (7) completion of corrective actions in a timely manner.
These activities constitute completion of one (1) in-depth problem identification and
resolution sample as defined in Inspection Procedure 71152-05.
b.
Findings
Introduction. The inspectors identified a noncited violation of 10 CFR Part 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, for station planning
personnels failure to adequately implement station Procedures EN-FAP-WM-011, Work
Planning Standard, Revision 0, and EN-WM-102, Planning, Revision 6.
Description. On August 3, 2010, while conducting a review of station work orders for
scheduled maintenance activities on safety related equipment, the inspectors noted
instances where these work orders were not written in accordance with the requirements
of Procedure EN-FAP-WM-011. Specifically, the inspectors noted that, contrary to the
requirements of Section 3.2.2 of this procedure, multiple reference level work orders
generated by the fix-it-now team contained blanket references to other procedures
without providing specific guidance to which sections were to be used, and specific
starting and stopping points. The inspectors informed the licensee of this issue and it
was entered into the corrective action program Condition Report CR-ANO-C-2010-1962.
Based on this observation, and the inspectors knowledge of past programmatic issues
with work order generation, the inspectors performed increased monitoring of station
work orders being generated for activities on safety related equipment. From August 17
through August 19, 2010, the inspectors noted additional instances where planning
personnel failed to appropriately implement procedural requirements associated with
work order generation requirements for emergent work performed on emergency diesel
generator 2K-4B.
Work Order 52026722, task 12, was generated to allow craft personnel to investigate
and repair issues associated with the loss of crank case vacuum of emergency diesel
generator 2K-4B, using the applicable steps of station procedures and system
engineering direction. This work order task had been designated as a reference level
task and provided the following work plan details:
4.2
INVESTIGATE/REPAIR using applicable steps of OP 2306.005 and
System engineering direction to determine the cause of the loss of vacuum and
over pressurization of the engine crankcase
4.3
ENSURE that any Temporary Services and Equipment used during the
performance of this task were removed, along with their applicable tag(s)
- 44 -
Enclosure 2
On August 18, 2010, during their review, the inspectors determined that the licensee
planned to install temporary equipment on the emergency diesel generator, for testing
activities, using the above guidance. However, there were no references available in
station procedures to provide direction for the proposed activities, and the work was
being done at the direction of the vendor. The inspectors determined that this was
contrary to the requirements of Procedure EN-WM-105, section 3[19], which defines a
reference package as, The level of detail is above skill of the craft but reference
material is available to provide all of the necessary guidance. This includes procedures,
work standards, vendor manuals and/or excerpts of these references, and
section 5.2[4].e, which states, For Reference packages the planner will identify what
needs to be done, and refer to approved references for work instructions. The
inspectors informed the licensee of this issue and it was entered into the corrective
action program as Condition Report CR-ANO-2-2010-1736.
On August 19, 2010, the inspectors again reviewed this task because a scope addition
had been performed to support installation of other temporary equipment on the
emergency diesel generator and the changing of the air ejector orifice using the above
guidance. The inspectors again questioned the lack of instructions for the temporary
equipment installation and the referencing of the vendor technical manual for the orifice
replacement without referencing the specific manual sections. The inspectors informed
the licensee of this issue and it was entered into the corrective action program as
Condition Report CR-ANO-C-2010-2114. In response to the inspectors questions, the
licensee reviewed the procedural requirements and the vendor technical manual and
determined that the vendor manual did not contain guidance on changing the orifice and
specific work instructions had to be generated for this task.
Analysis. The inspectors determined that the failure of station planning personnel to
follow Procedures EN-FAP-WM-011 and EN-WM-105 and to ensure that adequate
procedures were generated for maintenance conducted on safety-related equipment
was a performance deficiency. The performance deficiency was determined to be more
than minor because if left uncorrected it would become a more significant safety
concern. Specifically, the continued practice of generating inadequate work orders for
maintenance activities on safety-related equipment would have the potential to leave risk
significant equipment in a degraded condition without the knowledge and approval of site
management and operations personnel, and is therefore a finding. The finding was
associated with the Mitigating Systems Cornerstone. Using Manual Chapter 0609.04,
Phase 1 - Initial Screening and Characterization of Findings, the finding was
determined to have very low safety significance because the finding: (1) was not a
design or qualification issue confirmed not to result in a loss of operability or
functionality; (2) did not represent an actual loss of safety function of the system or train;
(3) did not result in the loss of one or more trains of nontechnical specification
equipment; and (4) did not screen as potentially risk significant due to a seismic,
flooding, or severe weather initiating event. The finding was determined to have a
crosscutting aspect in the area of human performance, associated with work practices
H.4(b) in that the licensee defines and effectively communicates expectations regarding
procedural compliance and personnel follow procedures.
- 45 -
Enclosure 2
Enforcement. Title 10 of the Code of Federal Regulations Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities
affecting quality shall be prescribed by documented instructions, procedures or
drawings, of a type appropriate to the circumstances and shall be accomplished in
accordance with these instructions, procedures, or drawings. Contrary to the above,
between August 3 through 19, 2010, multiple occasions were identified where station
planning personnel failed to follow Procedures EN-FAP-WM-011 and EN WM 105 and to
ensure that adequate procedures were generated for maintenance conducted on safety
related equipment. Because this finding is of very low safety significance and has been
entered into the corrective action program as Condition Reports CR-ANO-C-2010-1962,
CR-ANO-C-2010-1964, CR-ANO-2-2010-1736, CR-ANO-C-2010-2114,
CR-ANO-C-2010-2119, and CR-ANO-C-2010-2140, this violation is being treated as a
noncited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy:
NCV 05000368/2010004-08, Failure to Follow Procedures and Generate Adequate
Work Orders for Maintenance on Safety Related Equipment.
.5
Annual Sample: Review of Level 1 Tagging Errors During Unit 1 Refueling Outage 1R22
.a
Inspection Scope
The inspectors noticed an unusually high number of Level 1 tagging errors during the
most recent Unit 1 refueling outage. There were four tagging errors in a two week
period and one of the errors resulted in contaminated (reactor coolant system) water
inadvertently being drained to the containment basement. The inspectors reviewed
each issue and the roll up condition report and root cause associated with this issue.
.b
Findings
Introduction. The inspectors documented a green, self-revealing noncited violation of
Unit 1 Technical Specification 5.4.1.a for the failure to follow Procedure EN-OP-102,
Protective and Caution Tagging, Revision 12. Specifically, a maintenance tagout
holder signed off a tagout prior to all work being complete, which led to the removal of
the clearance. This resulted in draining the pressurizer to the containment basement
floor instead of to a drain tank.
Description. On March 31, 2010, while Unit 1 was in Mode 6, operations personnel
removed tags associated with the replacement of valve RBD-25 and performed a valve
lineup to drain the Unit 1 pressurizer during Refueling Outage 1R22. When operations
personnel began to drain the pressurizer through the pressurizer surge line drains, water
was identified running out from beneath the temporary shielding. Operations personnel
were promptly notified and the drain was secured. An investigation into the leakage
revealed that a spectacle flange had not been reassembled following completion of
welding activities in support of valve RBD-25 replacement.
This issue was entered into the corrective action program as Condition
Report CR-ANO-1-2010-1013. Mechanical maintenance personnel had removed the
flange on March 25, 2010. In accordance with Procedure EN-OP-102, the mechanical
maintenance lead should have remained on the tagout until the flange had been re-
- 46 -
Enclosure 2
installed. The mechanical maintenance war room coordinators (special team that
oversees mechanical maintenance during outages) incorrectly believed that as long as
another organization was on the tagout, as the tagout holder, all other work on the
tagout would be covered. The mechanical maintenance war room was also of the
mindset to minimize all personnel on the tagout to minimize the time it would take to
remove a tagout. As a result the mechanical war room supervision convinced the
mechanical maintenance lead to sign off on the tag-out before the flange had been
reassembled.
On March 30, 2010, the outage control center identified the work associated with the
RBD-25 valve replacement as being on critical path for draining the pressurizer. A
senior reactor operator was tasked to follow this work and ensure prompt removal of the
tagout as soon as possible. Welders, who were the only tagout holders on the tagout,
completed their work and signed off the tagout. The senior reactor operator failed to
recognize that all work had not been completed and removed the tagout. Operations
personnel were notified that the system was ready for use. Operations personnel
aligned the system for pressurizer drain and commenced draining. Soon after the
draining evolution had begun the pressurizer water was discovered draining onto the
containment building floor.
Analysis. The inspectors determined that the failure of station personnel to follow
Procedure EN-OP-102, Protective and Caution Tagging, Revision 12, was a
performance deficiency. The performance deficiency was determined to be more than
minor because if left uncorrected it could lead to a more significant safety issue.
Specifically, the continued failure to follow this procedure could lead to the inappropriate
release of systems and equipment to other organizations when these systems or
equipment are not capable of performing their function. This is therefore a finding.
Using NRC Manual Chapter 0609, Significance Determination Process, Appendix G,
"Shutdown Operations Significance Determination," Attachment 1, the finding was
determined to have very low safety significance because the finding did not affect core
heat removal, inventory control, power availability, and containment control or reactivity
guidelines. The finding was determined to have a crosscutting aspect in the area of
human performance, associated with work practices H.4(c), in that the licensee did not
ensure supervisory and management oversight of work activities such that nuclear
safety is supported. Specifically, instead of supplying appropriate guidance and
supervision for the workers in the field, the mechanical war room coordinators actions
resulted in the failure to follow procedure by convincing the mechanical lead to sign off
on the tagout before the work had been completed.
Enforcement. Technical Specification 5.4.1.a states, in part, that written procedures
shall be implemented in accordance with Regulatory Guide 1.33, Appendix A. Tagging
activities is one of the areas covered in Regulatory Guide 1.33, Appendix A. Contrary to
the above, the licensee failed to follow Procedure EN-OP-102, Protective and Caution
Tagging, Revision 12, and released a tagout that resulted in operations draining the
pressurizer to the Unit 1 reactor building basement floor. Because this finding is of very
low safety significance and has been entered into the corrective action program as
Condition Report CR-ANO-1-2010-1013, this violation is being treated as a noncited
- 47 -
Enclosure 2
violation consistent with Section 2.3.2.a of the NRC Enforcement Policy:
NCV 05000313/2010004-09, Failure to Follow Procedure Results in Draining Unit 1
Pressurizer to Reactor Building Floor.
.6
In-depth Review of Operator Workarounds
a.
Inspection Scope
The inspectors selected this issue for review to verify that licensee personnel were
identifying operator workaround problems at an appropriate threshold and entering them
in the corrective action program, and has proposed or implemented appropriate
corrective actions. The inspectors reviewed and evaluated the licensee's operator
workaround log, for both Units 1 and 2, operator logs and associated condition reports.
The inspectors considered the following, as applicable, during the review of the
licensee's actions: (1) complete and accurate identification of the problem in a timely
manner; (2) evaluation and disposition of operability/reportability issues;
(3) consideration of extent of condition, generic implications, common cause, and
previous occurrences; (4) classification and prioritization of the resolution of the problem;
(5) identification of root and contributing causes of the problem; (6) identification of
corrective actions; and (7) completion of corrective actions in a timely manner.
b.
Findings
No findings were identified.
4OA5 Other Activities
.1
(Closed) Temporary Instruction 2515/173, Review of the Implementation of the Industry
Groundwater Protection Voluntary Initiative, Revision 1
a.
Inspection Scope
An NRC assessment was performed of the licensees groundwater protection program to
determine whether the licensee implemented the voluntary Industry Groundwater
Protection Initiative, dated August 2007 (Nuclear Energy Institute 07-07, Industry
Groundwater Protection Initiative - Final Guidance Document, ADAMS Accession
Number ML072610036). The inspectors interviewed personnel, performed walkdowns
of selected areas, and reviewed the following items:
Records of the site characterization of geology and hydrology
Evaluations of systems, structures, and or components that contain or could
contain licensed material and evaluations of work practices that involve licensed
material for which there is a credible mechanism for the licensed material to
reach the groundwater
Implementation of an onsite groundwater monitoring program to monitor for
potential licensed radioactive leakage into groundwater
- 48 -
Enclosure 2
Procedures for the decision making process for potential remediation of leaks
and spills, including consideration of the long term decommissioning impacts
Records of leaks and spills recorded, if any, in the licensees decommissioning
files in accordance with 10 CFR 50.75(g)
Licensee briefings of local and state officials on the licensees groundwater
protection initiative
Protocols for notification to the local and state officials, and to the NRC regarding
detection of leaks and spills
Protocols and/or procedures for 30-day reports if an onsite groundwater sample
exceeds the criteria in the radiological environmental monitoring program
Groundwater monitoring results as reported in the annual effluent and/or
environmental monitoring report
Licensee and industry assessments of implementation of the groundwater
protection initiative
b.
Findings
No findings of significance were identified. Implementation of the Industry Groundwater
Protection Initiative is voluntary. Under the final initiative, each site was to have
developed an effective, technically sound groundwater protection program by
August 2008. At the time of the inspection, the inspectors determined that the licensee
had still not fully implemented the following objectives of Nuclear Energy Institute 07-07.
Additional monitoring wells are needed, according to the licensees consultants,
to adequately perform hydrogeologic and geologic studies to determine
groundwater flow characteristics and gradients, in accordance with
Objective 1.1a and to identify potential pathways for groundwater migration from
onsite locations to offsite locations, in accordance with Objective 1.1c.
No evaluation of work practices that involve or could reasonably be expected to
involve licensed material and for which there was a credible mechanism for the
licensed material to reach groundwater was conducted, in accordance with
Objective 1.2a.
Existing leak detection methods were not correlated to each system, structure,
and component and identified for each work practice that involves or could
involve licensed material for which there is a creditable potential for inadvertent
release to groundwater, in accordance with Objective 1.2b.
Potential enhancements were not identified to leak detection systems or
programs, in accordance with Objective 1.2c.
- 49 -
Enclosure 2
Potential enhancements to prevent spills or leaks from reaching the groundwater
were not identified, in accordance with Objective 1.2d.
Groundwater monitoring wells were not placed down gradient from the plant in
accordance with Objective 1.3a. Three wells were installed south to southwest of
the plant. However, data from these wells suggest the locations are not down
gradient of critical systems, structures, and components.
Sentinel wells were not placed near to systems, structures, and components that
have the highest potential for inadvertent releases that could reach groundwater,
in accordance with Objective 1.3b.
The procedure used for communicating actual release information to the
state/local officials, in accordance with Objective 2.2c, did not include all required
information.
The 2006 and 2007 groundwater sample results were not reported in the 2007
and 2008 annual radiological environmental operating report, respectively, in
accordance with Objective 2.4a.
Condition Report CR-HQN-2010-00207 was initiated to ensure implementation of
actions to address the items listed above.
.2
(Closed) Unresolved Item 05000313/2009005-07, Diesel Generator Ventilation Systems
Susceptibility to the Depressurization Effects of a Tornado
In NRC Inspection Report 05000313/2009005 inspectors opened an unresolved item
concerning the potential susceptibility of the Unit 1 emergency diesel generator heating,
ventilating and air conditioning ducting to loading effects caused by natural phenomena,
tornados. Inspectors reviewed this issue for closure and documented a noncited
violation (05000313/2010004-02) in Section 1R15 of this report.
.3
(Open) NRC Temporary Instruction 2515/177, Managing Gas Accumulation in
Emergency Core Cooling, Decay Heat Removal and Containment Spray Systems (NRC
As documented in Section 1R04, the inspectors confirmed the acceptability of the
described licensees actions. This inspection effort counts towards the completion of
TI 2515/177 which will be closed in a later Inspection Report.
- 50 -
Enclosure 2
- 51 -
Enclosure 2
.4
IP 92723, Follow Up Inspection for Three or More Severity Level IV Traditional
Enforcement Violations in the Same Area in a 12-Month Period
.a
Inspection Scope
The inspectors performed Inspection Procedure 92723 in accordance with the Arkansas
Nuclear One 2009 end of cycle assessment letter. Arkansas Nuclear One received four
traditional violations during the 2009 assessment period. The inspectors reviewed the
licensees condition reports for each violation and the roll up root cause analysis for the
following items:
Problem identification
Cause, extent of condition and extent of cause
Evaluation of corrective actions
.b
Findings
No findings were identified.
4OA6 Meetings
Exit Meeting Summaries
On, July 22, 2010, inspectors briefed Mr. B. Berryman, Acting Site Vice President, and other
members of the licensee's staff of the results of the licensed operator requalification program
inspection. The lead inspector obtained the final biennial examination results and telephonically
exited with Mr. R. Martin, Unit Operations Training Superintendent, on August 16, 2010. The
licensee representatives acknowledged the findings presented. The inspectors asked the
licensee whether any materials examined during the inspection should be considered
proprietary. No proprietary information was identified.
On July 23, 2010, inspectors presented the results of the radiation safety inspections to Mr. M.
Chisum, Acting General Manager, Plant Operations, and other members of the licensee staff.
The licensee acknowledged the issues presented. The inspectors asked the licensee whether
any materials examined during the inspection should be considered proprietary. No proprietary
information was identified.
On September 27, 2010, resident inspectors presented the inspection results to Mr. B.
Berryman, Acting Site Vice President and other members of the licensee staff. The licensee
acknowledged the issues presented. The inspectors asked the licensee whether any materials
examined during the inspection should be considered proprietary. No proprietary information
was identified.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
J. Bacquet, ALARA Supervisor, Radiation Protection
R. Beard, EP&C
B. Berryman, Acting Site Vice President
D. Bice, Acting Manager, Licensing
D. Calloway, Effluent and Environmental Monitoring Specialist, Chemistry
M. Chisum, Acting General Manager, Plant Operations
A. Clinkingbeard, Operations Training, Assistant Operations Manager
S. Cotton, Training Manager
R. Crowe, Superintendent, Security
S. Cupp, Simulator Superintendent
R. Dodds, Manager, Maintenance
R. Gresham, Senior Emergency Planner
R. Henry, EP&C
D. Hicks, Support Supervisor, Radiation Protection
D. James, Director, Nuclear Safety Assurance
J. James, Laboratory Technician, Chemistry
K. Jones, Manager, Operations
R. Jones, EP&C
J. McCoy, Acting Director, Engineering
D. Meatheany, EP&C
R. Martin, U1 Operations Training Superintendent
D. Marvel, Supervisor, Radiation Protection Operations
T. Nickels, ALARA Coordinator, Radiation Protection
K. Panthen, EP&C
M. Paterak, EP&C
J. Priore, Ventilation Systems Engineer, Systems Engineering
J. Smith, Manager, Radiation Protection
R. Starkey, Radwaste Supervisor, Radiation Protection
G. Stephenson, Effluent and Environmental Monitoring Specialist, Chemistry
T. Rolniak, Specialist, Radiation Protection
B. Short, Licensing Specialist
C. Simpson, U2 Operations Training Superintendent
D. Stringer, EP&C
G. Thompson, Supervisor, Chemistry
F. VanBuskirk, Licensing Specialist
A-1
Attachment
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
2515/177
TI
Managing Gas Accumulation in Emergency Core Cooling, Decay
Heat Removal and Containment Spray Systems (NRC Generic
Letter 2008-01) (Section 4OA5)
05000313;05000368/
2010004-05
Failure to Adequately Implement Foreign Material Exclusion
Controls (Section 1R20)
Opened and Closed 05000368/2010004-01 NCV
Excessive Overlap of Unit 2 Written Examinations (Section 1R11)05000313/2010004-02 NCV
Failure to Promptly Identify and Correct a Condition Adverse to
Quality Associated with Emergency Diesel Generators Heating,
Ventilation, and Air Conditioning Ducting Susceptibility to Tornado
Loading (Section 1R15)05000313/2010004-03 NCV
Failure to Promptly Identify and Correct a Condition Adverse to
Quality Associated with Emergency Switchgear Chiller VCH-4A
(Section 1R18). 05000313/2010004-04 FIN
Failure to Follow Station Work Control Procedure Results in
Unavailable Equipment (Section 1R19)05000313/2010004-06 NCV
Failure to Correctly Translate VCH-4B Design Requirements into
Installed Plant Equipment (Section 1R22)05000368/2010004-07 NCV
Failure to Provide an Accurate Shipping Manifest
(Section 2RS08)05000368/2010004-08 NCV
Failure to Follow Procedures and Generate Adequate Work
Orders for Maintenance on Safety Related Equipment
(Section 4OA2.4)05000318/2010004-09 NCV
Failure to Follow Procedure Results in Draining Unit 1 Pressurizer
to Reactor Building Floor (Section 4OA2.5)
Closed
2515/173
TI
Review of the Implementation of the Industry Groundwater
Protection Voluntary Initiative, Revision 1 (Section 4OA5)05000313/2009005-07 URI
Diesel Generator Ventilation Systems Susceptibility to the
Depressurization Effects of a Tornado (Section 4OA5)
A-2
Attachment
LIST OF DOCUMENTS REVIEWED
Section 1R04: Equipment Alignment
PROCEDURES
NUMBER
TITLE
REVISION
OP-2106.006
Emergency Feedwater System Operations
76
OP-1106.006
Emergency Feedwater Pump Operation
79 & 80
OP-1104.005
Reactor Building Spray System Operation
59
OP-2104.037
Alternate AC Diesel Generator Operations
19
OP-2104.036
Emergency Diesel Generator Operations
75
OP-1104.004
Decay Heat Removal Operating Procedure
90
DRAWINGS
NUMBER
TITLE
REVISION
M-2217 sheets 1-3 Unit 2 Emergency Diesel Generator Auxiliary Systems
M-2236 sheet 4
Unit 2 Emergency Feedwater System
66
E-2005 sheet 2
Alternate AC Generator System and 4.16KV Generation
and Switchgear
1
M-2204 sheet 1
Unit 2 Emergency Feedwater System
150
7-DH-1
Large Pipe Isometric Decay Heat Removal To Reactors
20
7-DH-3
Large Pipe Isometric Decay Heat Removal From Reactor
19
7-DH-4
Large Pipe Isometric Decay Heat Removal From Reactor
23
7-DH-5
Large Pipe Isometric Decay Heat Removal Pump
Discharge
9
7-DH-1 1
Large Pipe Isometric Decay Heat Removal Pump
Discharge
21
A-3
Attachment
7-DH-1 2
Large Pipe Isometric Engineered Safeguards Pump
Suction Header
20
M-232-1
Decay Heat Removal System
103
Section 1R05: Fire Protection
PROCEDURES
NUMBER
TITLE
REVISION
Arkansas Nuclear One Fire Hazard Analysis
13
ANO Prefire Plan (Unit 1)
12
ANO Prefire Plan (Unit 2)
10
DRAWINGS
NUMBER
TITLE
REVISION
FZ-1032
Unit 1 fire zone detail - north and south Emergency
Diesel Generator rooms
2
FZ-2039
Unit 2 fire zone detail - upper south electrical penetration
room
2
FZ-2051
Unit 2 fire zone detail - Hot Instrument shop, Tool Room
and Auxiliary Building Corridor
2
FZ-2045
Unit 2 fire zone detail - Electrical Equipment and Cable
Spreading room
2
Section 1R06: Flooding
PROCEDURES
NUMBER
TITLE
REVISION
ULD-0-TOP-17
ANO Topical Flooding
0
CALCULATION
NUMBER
TITLE
REVISION
CALC-89-E-0042-35
ANO-1 Internal Flooding Analysis
0
A-4
Attachment
CALC-92-R-0024-01
Flooding Evaluation INPO SOER 85-5
0
CALC-92-R-0034-01
Flooding Evaluation INPO SOER 85-5-2nd Iteration
0
Section 1R11: Licensed Operator Requalification
PROCEDURES
NUMBER
TITLE
REVISION
Licensed Operator Requalification Training Description
3
Conduct of Simulator Training
3
Systematic Approach to Training Process
13
Training Exemptions
1
MISCELLANEOUS DOCUMENTS
NUMBER
TITLE
REVISION /
DATE
Written Exams U1 and U2 Weeks 1 through 6 Biennial Exams (RO and SRO)
July 2010
U1 and U2 Reviewed weeks 1 through 6 for overlap
July 2010
1063.008
License Reactivation Procedure
39
ANO LERs
All 16 LERs from 2008-2010 for both Units
N/A
QA Audit Report for Training
February 2010
Simulator Test Steady State 100% Power
January 2010
Simulator Test Transient Test LOCA with LOOP
January 2010
Simulator Test Transient Test Load Reject from 100% Power
March 2010
DR-2007-0029 Simulator Closed Work Package
April 2007
DR-2010-0118 Simulator Open Work Package
February 2010
CONDITION REPORTS
ANO-2-2008-0924
ANO-2-2009-0254
ANO-2-2010-0327
ANO-2-2008-1318
ANO-2-2009-2002
ANO-2-2010-0764
ANO-2-2008-1761
ANO-2-2009-2207
ANO-2-2010-1460
ANO-2-2008-2056
ANO-2-2009-2321
ANO-2-2010-1830
ANO-2-2008-2609
ANO-2-2009-2352
ANO-2-2010-2056
ANO-2-2009-0145
ANO-2-2009-2391
A-5
Attachment
Section 1R12: Maintenance Effectiveness
PROCEDURES
NUMBER
TITLE
REVISION
1
Maintenance Rule Scope and Basis
1
Maintenance Rule Monitoring
2
Maintenance Rule (a)(1) Process
2
MISCELLANEOUS
TITLE
Unit 1 High Pressure Injection Maintenance Rule Database and Scoping Document
Unit 2 Emergency Feedwater Maintenance Rule Database and Scoping Document
Section 1R13: Maintenance Risk Assessment and Emergent Work Controls
PROCEDURES
NUMBER
TITLE
REVISION
COPD-024
Risk Assessment Guidelines
31
Section 1R15: Operability Evaluations
PROCEDURES
NUMBER
TITLE
REVISION
4
CONDITON REPORTS
ANO-2-2010-1158
ANO-2-2010-1229
ANO-2-2010-1402
ANO-2-2010-1009
ANO-C-2007-1308
ANO-C-2007-1469
A-6
Attachment
ANO-C-2009-2296
ANO-1-2010-2614
ANO-2-2010-1327
ANO-1-2010-2815
MISCELLANEOUS
NUMBER
TITLE
REVISION
Operability Input for CR-ANO-2-2010-1158 and CR-ANO-2-
2010-1229
Determine Effects of Tornado Induced DP Effects on EDG
Room Ductwork and Dampers Using Reg Guide 1.76 Rev.
1 Non-Design Basis Study Calc
ULD-1-STR-01
ANO-1 Auxiliary Building
1
Evaluation of the Ultimate Pressure Capacity of
Rectangular HVAC Ducts for Nuclear Power Plants (Volume
2 of ASCE Structural Engineering in Nuclear Facilities.)
Tornado Differential Pressure Effects on ANO-1 EDG Room
Duct Work and Damper
0
CALCULATION
NUMBER
TITLE
REVISION
CALC-09-E-0020-01
Maximum DP Across Ducts Serving the ANO-1 EDG
Rooms During A Tornado
0
CALC-09-E-0020-02
Maximum DP Across Ducts Serving the ANO-2 EDG
Rooms During A Tornado
0
CALC-09-E-0020-03
Tornado Induced DP Effects on EDG Room Ductwork and
0
Section 1R18: Plant Modifications
PROCEDURES
NUMBER
TITLE
REVISION
OP-1104.027
Battery and Switchgear Emergency Cooling System
35
A-7
Attachment
CONDITION REPORTS
ANO-1-2009-2122
ANO-1-2008-0098
Section 1R19: Postmaintenance Testing
PROCEDURES
NUMBER
TITLE
REVISION
OP-2104.036
Emergency Diesel Generator Operations
75
OP-2402.147
Unit 2, 2K-4 Diesel Engine Maintenance
5
CONDITION REPORTS
ANO-1-2010-2260
ANO-1-2010-2105
ANO-1-2010-1347
ANO-2-2010-1694
ANO-2-2010-1765
ANO-2-2010-1867
ANO-2-2010-1699
ANO-2-2010-1778
ANO-2-2010-1870
ANO-2-2010-1710
ANO-2-2010-1787
ANO-2-2010-1885
ANO-2-2010-1717
ANO-2-2010-1794
ANO-2-2010-1889
ANO-2-2010-1718
ANO-2-2010-1796
ANO-2-2010-1897
ANO-2-2010-1719
ANO-2-2010-1826
ANO-2-2010-1911
ANO-2-2010-1725
ANO-2-2010-1844
ANO-2-2010-1914
ANO-2-2010-1729
ANO-2-2010-1857
ANO-2-2010-1920
ANO-2-2010-1741
ANO-2-2010-1858
ANO-2-2010-1939
ANO-2-2010-1744
ANO-2-2010-1861
ANO-2-2010-1958
ANO-2-2010-1965
ANO-2-2010-1349
ANO-2-2010-1350
ANO-2-2010-1981
ANO-2-2010-1343
ANO-C-2010-2084
MISCELLANEOUS
NUMBER
TITLE
Evaluate VCH-4B Operability for temporary modification to remove lockout
feature for TS-6060
A-8
Attachment
Replace Containment Spray Flow Transmitter 2FT-5610
ULD-2-SYS-01
Emergency Diesel Generator System
WORK ORDERS
241315
52207054
242042
52026722
51667640
Section 1R20: Refueling and Other Outage Activities
PROCEDURES
NUMBER
TITLE
REVISION
OP-2102.001
Plant Pre-Heatup and Pre-Critical Checklist
68
5
WORK ORDERS
216672
162137
52236360
225146
224527
205511
158163
52032679
51670771
165587
214644
51695579
52024097
52218289
52195142
51683823
51697557
219285
51694251
51694250
51696279
52031347
247292
51697564
52242656
52215030
51696280
52215029
52201736
52224471
156861
52027898
51662172
241691
216670
51699369
201963
214536
52024097
162884
51699371
51699370
160017
216672
A-9
Attachment
216667
52026721
162884
225146
MISCELLANEOUS
NUMBER
TITLE
Evaluate Seismic Scaffold Erected in Unit 2 Containment for all Plant
Conditions
CONDITION REPORTS
ANO-1-2008-2491
ANO-2-2009-2843
ANO-2-2010-1839
ANO-2-2010-1868
ANO-C-2009-0720
ANO-C-2010-0688
ANO-C-2010-1570
ANO-C-2010-2192
ANO-C-2010-2684
Section 1R22: Surveillance Testing
PROCEDURES
NUMBER
TITLE
REVISION
OP-1106.006
Unit 1 Emergency Feedwater Pump Operation
80
OP-1104.027
Unit 1 Battery and Switchgear Cooling System
35
OP-2304.236
Unit 2 Emergency Feedwater Flow and Pressure Green
Channel Calibration
12
OP-1104.029
Service Water and Auxiliary Cooling System
77
OP-1305.018
Local Leak Rate Testing-Type C
20
OP-2104.005
59
OP-2104.036
Emergency Diesel Generator Operations
68
OP-1103.013
RCS Leak Detection
34
OP-2305.002
Reactor Coolant System Leak Detection
21
52205155
A-10
Attachment
MISCELLANEOUS
TITLE
Equipment Qualification Data Record Sheets 2B010, 2B007, and 2A247
CONDITION REPORTS
ANO-1-2010-0653
ANO-1-2010-0754
Section 2RS06: Radioactive Gaseous and Liquid Effluent Treatment
AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES
NUMBER
TITLE
DATE
QA-216-2009-ANO-1 Combined Chemistry, Effluents, and Environmental
Monitoring
August 7, 2009
COMPENSATORY SAMPLING
UNIT
MONITOR
DATE
2
SPING 7
October 13, 2009
2
SPING 7
October 31, 2009
CORRECTIVE ACTION DOCUMENTS
C-2008-01583
2-2009-00360
C-2008-01778
1-2010-01657
1-2010-02067
2-2009-01917
2-2009-00386
1-2009-01300
1-2009-02288
1-2010-00089
C-2010-01373
1-2010-00101
2-2009-00350
C-2008-01612
IN-PLACE FILTER TESTING RECORDS
SYSTEM
WORK ORDER
DATE
Penetration Room Ventilation (VEF-38A) 51561623
May 7, 2009
Penetration Room Ventilation (VEF-38B) 51547088
February 3, 2009
VSF-9 Emergency Air Recirculation
51547584
February 3, 2009
51557857
May 6, 2009
MISCELLANEOUS DOCUMENTS
TITLE
Annual Radioactive Effluent Release Report for 2008
Annual Radioactive Effluent Release Report for 2009
A-11
Attachment
PROCEDURES
NUMBER
TITLE
REVISION
1052.003
Nuclear Chemistry Quality Control Program
26
1604.015
Analysis of Unit Vent
17
2607.010
Sampling the Unit 2 Vents
16
RELEASE PERMITS
2GR 2009-0136
2 GR 2009-0150
2GR 2009-0153
1LR 2009-0059
Section 2RS07: Radiological Environmental Monitoring Program
AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES
NUMBER
TITLE
DATE
QA-2/6-2009-ANO-1 Quality Assurance Audit Report; Combined
Chemistry, Effluents and Environmental Monitoring
August 7,2009
CONDITION REPORTS
C-2008-01067
C-2008-02584
C-2009-00016
C-2009-00714
C-2009-00605
C-2009-00621
C-2009-00926
1-2009-01046
2-2009-01635
C-2010-00077
C-2010-00323
C-2010-00551
C-2010-01074
MISCELLANEOUS DOCUMENTS
NUMBER
TITLE
DATE
Perform the Semi-Annual Meterological Monitoring
Calibration
April 2, 2010
PROCEDURES
NUMBER
TITLE
REVISION/DATE
1608.005
Radiological Environmental Monitoring Program
35
1042.003
RadioChemistry Routine Surveillance Schedule and
Tech. Spec. Reporting
27
1012.018
Administration of Radiological Surveys
12
Annual Radiological Environment Operating Report
for 2009
May 11, 2010
Annual Radiological Environment Operating Report
for 2008
May 13, 2009
A-12
Attachment
Section 2RS08: Radioactive Solid Waste Processing and Radioactive Material Handling,
Storage, and Transportation
CONDITION REPORTS
ANO-C-2009-1008
ANO-C-2009-1039
ANO-C-2009-2051
MISCELLANEOUS
NUMBER
TITLE
DATE
199825001
10 CFR Part 61 Analysis for DAW Smears
April 11, 2008
199825007-1 10 CFR Part 61 Analysis for Oil
October 2, 2008
199825003
10 CFR Part 61 Analysis for Unit 1 RCS
October 2, 2008
224919001
10 CFR Part 61 Analysis for DAW Smears
March 31, 2009
218075001
10 CFR Part 61 Analysis for Unit 2 RCS
October 7, 2009
Annual Radioactive Effluent Release Report for 2008
PROCEDURES
NUMBER
TITLE
REVISION
EN-RW-101 Radioactive Waste Management
2
EN-RW-102 Radioactive Shipping Procedure
7
EN-RW-104 Scaling Factors
6
EN-RW-105 Process Control Program
1
1601.506
Radioactive Waste Management Program Surveillances
2
RADIOACTIVE MATERIAL SHIPMENTS
NUMBER
TITLE
DATE
RSR-09-051
20 Unit 2 SFP Filters
May 19, 2009
RSR-09-110
5 Gallon Drum with Alpha Smears
October 12, 2009
RSR-10-053
Unit 1 Primary Resin Samples
April 28, 2010
RSR-10-059
P-32C RCP Motor Impeller
May 3, 2010
Section 40A2: Identification and Resolution of Problems
PROCEDURES
NUMBER
TITLE
REVISION
OP-2304.134
Unit 2 EDG 2K-4A Instrument Calibration
19
A-13
Attachment
Planning
7
OP-2304.126
Unit 2 Containment Temperature and Dewpoint Instrument
Calibration
15
EN-FAP-WM-11
Work Planning Standard
0
CONDITION REPORTS
ANO-2-2010-1736
ANO-2-2010-1350
ANO-2-2010-1865
ANO-C-2010-1575
ANO-C-2010-1962
ANO-C-2010-1964
ANO-C-2010-2114
ANO-C-2010-2119
ANO-C-2010-2140
ANO-2-2010-1751
ANO-C-2010-2132
WORK ORDERS
83251
205016
51801189
209815
243722
244246
52026722
Section 4OA5: Other Activities
MISCELLANEOUS
TITLE
REVISION/DATE
Annual Radiological Environment Operating Report for 2009
May 11, 2010
Annual Radiological Environment Operating Report for 2008
May 13, 2009
NEI Groundwater Protection Initiative, NEI Peer Assessment Report
December 10, 2009
Tritium in Groundwater Evaluation Arkansas Nuclear One
July 26, 2006
GPI Data Review Arkansas Nuclear One
April 2009
Groundwater Monitoring Plan
2
PROCEDURES
NUMBER
TITLE
REVISION
Monitoring of Nonradioactive Systems
3
Radiological Groundwater Monitoring Program
0
Buried Piping and Tanks Inspection and Monitoring Program
2
Response to Contaminated Spills/Leaks
4
A-14
Attachment
A-15
Attachment
CONDITION REPORTS
ANO-C-2010-01373 ANO-C-2010-0493
ANO-C-2009-2590
ANO-C-2009-0445
ANO-1-2009-0281
ANO-C-2009-1415