IR 05000313/2012002

IR 05000313-12-002; 05000368-12-002; 01/1/2012-03/31/2012; Arkansas Nuclear One, Integrated Resident and Regional Report; Radiation Monitoring Instrumentation; Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage

ML12132A371
Person / Time
Site:	Arkansas Nuclear
Issue date:	05/11/2012
From:	Allen D NRC/RGN-IV/DRP/RPB-E
To:	Schwarz C Entergy Operations
References
IR-12-002
Download: ML12132A371 (55)

Text

May 11, 2012

SUBJECT:

ARKANSAS NUCLEAR ONE - NRC INTEGRATED INSPECTION REPORT NUMBER 05000313/2012002 AND 05000368/2012002

Dear Mr. Schwarz:

On March 31, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Arkansas Nuclear One, Units 1 and 2. The enclosed inspection report documents the inspection results which were discussed on April 12, 2012 with you and other 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 NRC identified finding of very low safety significance (Green) was identified during this inspection.

This finding was determined to involve a violation of NRC requirements. Additionally, the NRC has determined that a traditional enforcement Severity Level IV violation occurred. This traditional enforcement violation was identified with an associated finding. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest these non-cited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Arkansas Nuclear One.

If you disagree with a cross-cutting aspect assignment 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.

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION IV

1600 EAST LAMAR BLVD ARLINGTON, TEXAS 76011-4511 In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide Document Access and Management 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/

Donald B. Allen, Chief, Project Branch E Division of Reactor Projects

Docket Nos.: 05000313, 05000368 License Nos.: DRP-51, NPF-6

Enclosure: Inspection Report 05000313/2012002 and 05000368/2012002 w/ Attachment: Supplemental Information

cc w/ encl: Electronic Distribution

SUMMARY OF FINDINGS

IR 05000313/2012002; 05000368/2012002; 01/1/2012-03/31/2012; Arkansas Nuclear One,

Integrated Resident and Regional Report; Radiation Monitoring Instrumentation; Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage, and Transportation.

The report covered a 3-month period of inspection by resident inspectors and an announced baseline inspections by region-based inspectors. Two non-cited violations of significance 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. The cross-cutting aspect is 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.

Cornerstone: Occupational Radiation Safety

Green.

The inspectors identified a non-cited violation of 10 CFR 20.1501(b) because the licensee failed to calibrate Unit 1 effluent and process monitors properly. The Unit 1 calibration procedures did not instruct the instruments and controls technician to correct the calibration source output for radioactive decay, nor did the procedures provide criteria for determining when the calibration was successful. As immediate corrective action, the licensee documented the violation in the corrective action program as Condition Report CR-ANO-1-2012-0524, and reviewed the count rates of Unit 1 effluent and process monitors to determine the extent of the condition.

The failure to calibrate the Unit 1 effluent and process monitors properly is a performance deficiency. The performance deficiency is more than minor because, if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern, in that, radiation monitor performance could deteriorate and go undetected by the current Unit 1 calibration process. The inspectors used IMC 0609, Significance Determination Process, Attachment D, Public Radiation Safety Significance Determination Process, February 12, 2008, and determined the finding to be of very low safety significance because it was associated with the effluent program; however it was not a substantial failure to implement the effluents program and it did not result in a public dose greater than an Appendix I criterion or 10 CFR 20.1301(e). The finding has a cross-cutting aspect in the Human Performance Area, associated with the resources component, because complete, accurate, and up-to-date calibration procedures were not available for use on Unit 1 effluent and process monitors. H.2(c) (Section 2RS05)

• Severity Level IV. Inspectors identified a non-cited violation of 10 CFR 50.71(e),

Maintenance of Records, because the licensee failed to update their Safety Analysis Report with adequate details and submittals that include the effects of changes made to the facility. Specifically, the licensee built numerous low level radwaste storage facilities on the owner controlled area for interim radwaste storage of dry and solidified radioactive waste and failed to update the Safety Analysis Report to adequately include these changes to equipment, processes, and facilities.

This issue was entered in the licensees corrective action program as Condition Report CR-ANO-C-2012-00749.

This issue was dispositioned using traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. The performance deficiency is more than minor, thus characterized as a finding, because it has a material impact on licensed activities in that solid radwaste equipment and processes, as well as stored radwaste materials with a significant radioactive source term, have not been adequately described and maintained in all licensee records and reports. There was no cross-cutting aspect associated with this finding because it was dispositioned using traditional enforcement. This finding is characterized as a Severity Level IV non-cited violation in accordance with NRC Enforcement Policy,

Section 6.1 and was treated as a non-cited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy (Section 2RS08).

Licensee-Identified Violations

None

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at 100 percent reactor power. On January 6, 2012, Unit 1 reduced power to 49 percent reactor power to support offsite Mabelvale 500 KV tower maintenance. Following completion of the Mabelvale 500 KV tower maintenance, Unit 1 returned to 100 percent reactor power on January 8, 2012. On March 2, 2012, Unit 1 reduced power to 86 percent reactor power to support repair of an electro-hydraulic control system leak on the solenoid valve for the number 4 main turbine governor valve. On March 2, 2012, after the hydraulic leak was repaired, Unit 1 returned to 100 percent reactor power and remained there for the remainder of the report period.

Unit 2 began the inspection period at 100 percent reactor power and remained there for the report period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Readiness for Impending Adverse Weather Conditions

a.

Since thunderstorms with potential tornados and high winds were forecast in the vicinity of the facility for February 28-29, 2012, the inspectors reviewed the plant personnels overall preparations/protection for the expected weather conditions. On February 28-29, 2012, the inspectors walked down the service water intake structure and intake system, and the transformer yards because their safety-related functions could be affected, or required, as a result of high winds or tornado-generated missiles or the loss of offsite power. The inspectors evaluated the plant staffs preparations against the sites procedures and determined that the staffs actions were adequate. During the inspection, the inspectors focused on plant-specific design features and the licensees procedures used to respond to specified adverse weather conditions. The inspectors also toured the plant grounds to look for any loose debris that could become missiles during a tornado. The inspectors also evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant. Additionally, the inspectors reviewed the Safety Analysis Report (SAR) and performance requirements for the systems selected for inspection, and verified that operator actions were appropriate as specified by plant-specific procedures. The inspectors also reviewed a sample of corrective action program items to verify that the licensee identified adverse weather issues at an appropriate threshold and dispositioned them through the corrective action program in accordance with station corrective action procedures. Specific documents reviewed during this inspection are listed in the attachment.

Inspection Scope

These activities constitute completion of one readiness for impending adverse weather condition sample as defined in Inspection Procedure 71111.01-05.

b.

No findings were identified.

Findings

1R04 Equipment Alignment

.1 Partial Walkdown

a.

The inspectors performed partial system walkdowns of the following risk-significant systems:

Inspection Scope

• January 10, 2012, Unit 1 and Unit 2 emergency diesel generators while the alternate AC diesel generator was out of service for maintenance

• February 15, 2012, Unit 2 train A of emergency feedwater system while train B was out of service for maintenance

• March 1, 2012, Unit 1 high pressure injection pump, P-36A, (red train) while performing maintenance on the green train injection valves

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, SAR, technical specification requirements, administrative technical specifications, outstanding work orders, condition reports, and 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 three partial system walkdown samples as defined in Inspection Procedure 71111.04-05.

b.

No findings were identified.

Findings

1R05 Fire Protection

.1 Quarterly Fire Inspection Tours

a.

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:

Inspection Scope

• January 12, 2012, Unit 1, Fire Zone 1031, Unit 1 diesel fuel storage vault

• January 12, 2012, Unit 2, Fire Zone 2030, Unit 2 diesel fuel storage vault

• March 20, 2012, Unit 1, Fire Zone 104-S, Unit 1 south electrical equipment room

• March 31, 2012, Unit 1, Fire Zone 167B, control rod drive ac breaker room

• March 31, 2012, Unit 2, Fire Zone 2154-E, control element drive mechanism equipment 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 five quarterly fire-protection inspection samples as defined in Inspection Procedure 71111.05-05.

b.

No findings were identified.

Findings

1R06 Flood Protection Measures

a.

The inspectors reviewed the SAR, 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 areas 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.

Inspection Scope

• March 22, 2012, Unit 1, manhole number 4 which contains two trains of Unit 1 service water electrical power cables

These activities constitute completion of one manhole sample as defined in Inspection Procedure 71111.06-05.

b.

No findings were identified.

Findings

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 a.

Quarterly Review of Licensed Operator Requalification Program On March 15, 2012 the inspectors observed a crew of Unit 2 licensed operators in the plants simulator during requalification training. On March 16, 2012 the inspectors observed a crew of Unit 1 licensed operators in the plants simulator during requalification testing. The inspectors assessed the following areas:

Inspection Scope

• Licensed operator performance

• The ability of the licensee to administer the evaluations and the quality of the training provided

• The modeling and performance of the control room simulator

• The quality of post-scenario critiques

• Follow-up actions taken by the licensee for identified discrepancies and for operators who failed an evaluation

These activities constitute completion of one quarterly licensed operator requalification program sample as defined in Inspection Procedure 71111.11.

b.

No findings were identified.

Findings

.2 Quarterly Observation of Licensed Operator Performance

a.

On March 2, 2012, the inspectors observed the performance of on-shift licensed operators in the Unit 1 control room. At the time of the observations, the plant was in a period of heightened risk due to reducing reactor power to repair a leaking servo-control valve, SV-8519 and subsequent main turbine governor valve testing.

Inspection Scope

In addition, the inspectors assessed the operators adherence to plant procedures, including OP-1015.001, Conduct of Operations, Revision 90 and other operations department policies.

These activities constitute completion of one quarterly licensed-operator performance sample as defined in Inspection Procedure 71111.11.

b.

No findings were identified.

Findings

1R12 Maintenance Effectiveness

a.

The inspectors evaluated degraded performance issues involving the following risk significant systems:

Inspection Scope

• Maintenance Rule program (a)(3) assessment for period from January 2010 to June 2011.

• Unit 1 service water 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 in 10 CFR 50.65(a)(1)

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 quarterly maintenance effectiveness samples as defined in Inspection Procedure 71111.12-05.

b.

No findings were identified.

Findings

1R13 Maintenance Risk Assessments and Emergent Work Control

a.

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:

Inspection Scope

• January 11 and 19, 2012, Unit 1 while performing pressurizer sample via containment isolation valve SV-1818

• February 14, 2012, Unit 2, maintenance on motor driven emergency feedwater pump room cooler, 2VUC-6B, which rendered the pump inoperable

• February 15, 2012, Unit 1, loss of integrated control system automatic control of main feedwater low-load and startup valves

• February 28-29, 2012, Unit 2, postponement of train B service water pump outage while performing channel D of plant protection system and severe weather (tornado watch) in effect

• March 6, 2012, Unit 2, change in risk profile due to loss of two charging pumps, 2P-36B and 2P-36C

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.

These activities constitute completion of five maintenance risk assessments and emergent work control inspection samples as defined in Inspection Procedure 71111.13-05.

b.

No findings were identified.

Findings

1R15 Operability Evaluations and Functionality Assessments

a.

The inspectors reviewed the following assessments:

Inspection Scope

• January 20, 2012, Unit 1, SV-1818 pressurizer sample valve displaying dual position indication

• February 29, 2012, Unit 2, weld flaw leak on service water loop II instrument line

• March 6, 2012, Unit 1, emergency diesel generator fuel transfer pump following spurious actuation of fire system deluge system

• March 26, 2012, Unit 2, high pressure safety injection pump 2P-89C motor outboard bearing low oil level

• March 27, 2012, Unit 2, control element assembly issues with delayed element movement given withdrawal and insert command

• March 28, 2012, Unit 2, extension of service water pump, 2P-4B, operability evaluation due to degraded pump shaft sleeve

The inspectors selected these operability and functionality assessments based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure technical specification operability was properly justified and to verify the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and SAR to the licensees 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. Additionally, the inspectors 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 six operability evaluations inspection sample(s)as defined in Inspection Procedure 71111.15-05.

b.

No findings were identified.

Findings

1R19 Post-Maintenance Testing

a.

The inspectors reviewed the following post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

Inspection Scope

• January 12, 2012, Alternate AC diesel generator following planned maintenance

• January 18, 2012, CV-1219 and CV-1278, red train high pressure injection block valves following planned maintenance

• January 20, 2012, Unit 2, service water pump, 2P-4B, following electrical and mechanical maintenance

• February 1, 2012, Unit 1, decay heat pump, P-34B, following planned maintenance

• February 14, 2012, Unit 2, following emergency feedwater pump room cooler, 2VUC-6B, coupling replacement

• February 15, 2012, Unit 1, following replacement of several transfer relay cards in the integrated control system for control of low-load, CV-2673 and start-up, CV-2623 feedwater control valves

• February 24, 2012, Unit 1, service water pump, P-4C, following shaft sleeve replacement

• March 1, 2012, Unit 1, CV-1227, CV-1228, CV-1284, and CV-1285 green train high pressure injection block valves, following planned maintenance

• March 9, 2012, Unit 2, charging water pump, 2P-36C, after shaft replacement

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 (as applicable):

• 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 SAR, 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 post-maintenance 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 of nine post-maintenance testing inspection samples as defined in Inspection Procedure 71111.19-05.

b.

No findings were identified.

Findings

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the SAR, 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

• Test equipment

• Procedures

• Test data

• Testing frequency and method demonstrated technical specification operability

• Restoration of plant systems

• 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.

• January 23, 2012, Unit 1, high pressure injection pump, P-36C, quarterly inservice test.

• February 21, 2012, Unit 1, emergency feedwater initiation and control system channel B monthly surveillance test

• February 27-28, 2012, Unit 2, D32 battery charger load test

• March 1, 2012, Unit 1, high pressure injection pump, P-36B, quarterly inservice test

• March 2, 2012, Unit 1, main turbine control valve and stop valve surveillance testing

• March 20, 2012, Unit 2, low pressure safety injection pump, 2P-60B, quarterly inservice test and piping inservice inspection

• March 26, 2012, Unit 2, control element assembly quarterly exercise test

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of seven surveillance testing inspection samples as defined in Inspection Procedure 71111.22-05.

b.

No findings were identified.

Findings

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a.

The inspectors evaluated the conduct of a routine licensee emergency drill on February 27, 2012, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the control room simulator, technical support center, and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the corrective action program. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the attachment.

Inspection Scope

These activities constitute completion of one sample as defined in Inspection Procedure 71114.06-05.

b.

No findings were identified.

Findings

.2 Training Observations

a.

The inspectors observed a simulator training evolution for licensed operators on January 26, 2012, which required emergency plan implementation by a licensee operations crew.

This evolution was planned to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that the licensee evaluators noted the same issues and entered them into the corrective action program.

As part of the inspection, the inspectors reviewed the scenario package and other documents listed in the attachment.

Inspection Scope

These activities constitute completion of one sample as defined in Inspection Procedure 71114.06-05.

b.

No findings were identified.

Findings

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS0 5 Radiation Monitoring Instrumentation

a. Inspection Scope

This area was inspected to verify the licensee was assuring the accuracy and operability of radiation monitoring instruments that are used to:

(1) monitor areas, materials, and workers to ensure a radiologically safe work environment; and

(2) detect and quantify radioactive process streams and effluent releases. The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensees procedures required by technical specifications as criteria for determining compliance.

During the inspection, the inspectors interviewed licensee personnel, performed walkdowns of various portions of the plant, and reviewed the following items:

• Selected plant configurations and alignments of process, postaccident, and effluent monitors with descriptions in the Safety Analysis Report and the offsite dose calculation manual

• Select instrumentation, including effluent monitoring instrument, portable survey instruments, area radiation monitors, continuous air monitors, personnel contamination monitors, portal monitors, and small article monitors to examine their configurations and source checks

• Calibration and testing of process and effluent monitors, laboratory instrumentation, whole body counters, postaccident monitoring instrumentation, portal monitors, personnel contamination monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air samplers, continuous air monitors

• Audits, self-assessments, and corrective action documents related to radiation monitoring instrumentation 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 71124.05-05.

b. Findings

Introduction.

The inspectors identified a Green, non-cited violation of 10 CFR 20.1501(b) because the licensee failed to calibrate Unit 1 effluent and process monitors properly.

Description.

One part of a typical radiation instrument calibration involves a comparison of the instruments indicated value with a known value. In this case, the indicated counts per minute provided by the instrument is compared with the known disintegration rate of a radioactive source. To have the correct disintegration rate of the radioactive source, the individual performing the calibration must take into account the half-life of the radionuclide and the activity of the radioactive source on a known date. However, when the inspectors reviewed the Unit 1 and Unit 2 effluent and process monitor calibration records, they observed the Unit 1 calibration procedures did not instruct the instruments and controls technician to correct the calibration source output for radioactive decay, nor did the procedures provide criteria for determining when the calibration was successful.

Instead, the procedure instructed the technician to compare the calibration source count rate with the last calibration reading and inform Operations if a significant difference was observed. Significant was not defined. Based on these technical omissions and an interview of two Unit 1 instruments and controls technicians, the inspectors concluded the Unit 1 effluent and process monitors were not calibrated properly. In contrast, the Unit 2 calibration procedures provided the original transfer calibration source count rate from the primary calibration for each effluent and process monitor, the date on which the count rate was taken, instructions on how to decay correct the calibration source count rate, and a statement that the final count rates were acceptable if between 80 to 120 percent of the calculated (decay corrected) value. After performing independent verification of the decay-corrected monitor count rates, the inspectors concluded the Unit 2 effluent and process monitors were calibrated properly. Based on a review of procedure revisions, the inspectors determined the Unit 1 procedures omitted the necessary technical guidance in 2003.

The licensee retrieved the original transfer calibration source count rate from the primary calibration for each Unit 1 effluent and process monitor, corrected the count rates for radioactive decay, and then compared the corrected count rates with the as-left count

rates from the most recent calibrations. The licensee found the Unit 1 effluent and process monitor count rates were between 76 to 101 percent of the calculated values with all, except one, of the monitors reading below the calculated value. The count rate of one Unit 1 monitor was outside the +/- 20 percent allowable tolerance band used in Unit 2. RE-3814, a radiation monitor with an alarm function on the service water and intermediate cooling water systems, read 24 percent low, using the as-left count rate observed during the monitors calibration on January 24, 2011.

Analysis.

The failure to calibrate the Unit 1 effluent and process monitors properly is a performance deficiency. The performance deficiency is more than minor because, if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern, in that radiation monitor performance could deteriorate and go undetected by the current Unit 1 calibration process. The inspectors used IMC 0609, Significance Determination Process, Attachment D, Public Radiation Safety Significance Determination Process, February 12, 2008, and determined the finding to be of very low safety significance because it was associated with the effluent program; however, it was not a substantial failure to implement the effluents program and it did not result in a public dose greater than an Appendix I criterion or 10 CFR 20.1301(e). The finding has a cross-cutting aspect in the Human Performance Area associated with the resources component because complete, accurate, and up-to-date calibration procedures were not available for use on Unit 1 effluent and process monitors. H.2(c)

Enforcement.

10 CFR 20.1501(b) requires the licensee ensure that instruments and equipment used for quantitative radiation measurements are calibrated periodically for the radiation measured. Contrary to the above, the licensee did not calibrate some instruments used for quantitative radiation measurements periodically. Specifically, since 2003, the licensee did not use a process which calibrated the Unit 1 effluent and process monitors by comparing the observed count rate with a known or calculated count rate and the process did not ensure the instruments performance was within an established acceptance band. As immediate corrective action, the licensee documented the violation in the corrective action program and reviewed the count rates of Unit 1 effluent and process monitors to determine the extent of the condition.

Because this violation was of very low safety significance and was documented in Condition Report CR-ANO-1-2012-00524, it is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000313/2012002-01, Failure to Calibrate Unit 1 Effluent and Process Monitors Properly.

2RS0 6 Radioactive Gaseous and Liquid Effluent Treatment

a. Inspection Scope

This area was inspected to:

(1) ensure the gaseous and liquid effluent processing systems were maintained so radiological discharges were 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, were 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 were satisfied so discharges of radioactive materials were 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 interlaboratory 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

• 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.

2RS0 7 Radiological Environmental Monitoring Program

a. Inspection Scope

This area was inspected to:

(1) ensure that the radiological environmental monitoring program verified the impact of radioactive effluent releases to the environment and sufficiently validated the integrity of the radioactive gaseous and liquid effluent release program;

(2) verify that the radiological environmental monitoring program was 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 pathways was based on sound principles and assumptions and validated that doses to members of the public were 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 ground water

• 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

• Interlaboratory 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 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, 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 Severity Level IV non-cited violation of 10 CFR Part 50.71, Maintenance of Records, because the licensee failed to update its Safety Analysis Report (SAR) with adequate information relative to its solid radwaste equipment, processes, and facilities.

Description.

The inspector observed facilities in which the licensee stored solid radioactive waste on the owner controlled area. The licensee defined solid radioactive waste as spent demineralizer resins, filter elements, contaminated clothing, contaminated equipment, as well as paper, rags, and plastics used in decontamination and contamination control. The inspectors asked a licensing representative how long the buildings had been in place. The representative provided the following information:

The low level radwaste storage building located northeast of Unit 2, adjacent to the switchyard, was built in late 1986 or early 1987. The old radwaste storage building located east of Unit 1 turbine building was in place since the start of plant operation.

Warehouse 2, located east of Unit 1 turbine building and adjacent to the old radwaste storage building, was also in place since the start of plant operation. The Unit 2 steam generator mausoleum, outside the protected area, was built in late 1999 or early 2000.

The Unit 1 steam generator and head mausoleum, outside the protected area, was built in 2005.

The SAR lacked details of these facilities regarding their volume and/or construction, principal sources of radioactivity stored, and estimated dose rate at the site boundary per curie of stored waste. Because of the special nuclear material, old steam generators, and old reactor vessel heads stored in these facilities, the inspectors concluded that there was a significant source of radioactivity not adequately described in the licensees SAR. When this situation was identified by the NRC, the licensee was unable to provide the total amount of radioactivity (in curies) for these locations of stored waste materials nor could the licensee provide an estimate of dose rate at the site boundary per curie of stored waste. Additionally, the Warehouse 2 storage facility was not discussed in any detail in the SAR reviewed.

Analysis

. The performance deficiency associated with this finding was failure of the licensee to update its SAR with adequate information and submittals relative to its solid radwaste equipment, processes, and facilities. This issue was dispositioned using traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. The finding is characterized as a Severity Level IV, non-violation in accordance with NRC Enforcement Policy, Section 6.1. Since this issue was dispositioned using traditional enforcement, there is no cross-cutting aspect.

Enforcement.

Title 10 CFR 50.71(e), Maintenance of Records, requires, in part, that each person licensed to operate a nuclear power reactor shall update periodically the final safety analysis report (FSAR). This submittal shall contain all the changes necessary to reflect information and analyses submitted to the Commission by the licensee pursuant to Commission requirements since the submittal of the last update to the FSAR. The submittal shall include the effects of all changes made in the facility as described in the FSAR; all safety analyses and evaluations performed by the licensee in support of conclusions that changes did not require a license amendment in accordance with 10 CFR 50.59(c)(2).

Contrary to the above, since 1986, the licensee failed to include in a submittal the effects of all changes made in the facility as described in the SAR. Specifically, the licensee failed to update the solid radioactive waste program with adequate details and descriptions of equipment, facilities, and processes. This includes details of an additional solid radwaste storage area, principal radionuclides, and associated curie content or radioactivity of stored radioactive solid waste. As immediate corrective action, the licensee documented the violation in the corrective action program. Because the finding was a Severity Level IV violation and has been entered into the licensees corrective action program as Condition Report CR-ANO-C-2012-00749, the finding is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy: NCV 05000313/2012002-02; 05000368/2012002-02, Failure to Update the SAR with Adequate Details relative to its Solid Radwaste Equipment, Processes, and Facilities.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection

4OA1 Performance Indicator Verification

.1 Data Submission Issue

a.

The inspectors performed a review of the performance indicator data submitted by the licensee for the fourth Quarter 2011 performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, Performance Indicator Program.

Inspection Scope

This review was performed as part of the inspectors normal plant status activities and, as such, did not constitute a separate inspection sample.

b.

No findings were identified.

Findings

.2 Unplanned Scrams per 7000 Critical Hours (IE01)

a.

The inspectors sampled licensee submittals for the unplanned scrams per 7000 critical hours performance indicator for ANO Unit 1 and Unit 2 for the period from the 1st quarter 2011 through the 4th quarter 2011. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors reviewed the licensees operator narrative logs, issue reports, event reports, and NRC integrated inspection reports for the period of January 2011 through December 2011 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

Inspection Scope

These activities constitute completion of two unplanned scrams per 7000 critical hours samples as defined in Inspection Procedure 71151-05.

b.

No findings were identified.

Findings

.3 Unplanned Power Changes per 7000 Critical Hours (IE03)

a.

The inspectors sampled licensee submittals for the unplanned power changes per 7000 critical hours performance indicator for ANO Unit 1 and Unit 2 for the period from the 1st quarter 2011 through the 4th quarter 2011. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors reviewed the licensees operator narrative logs, issue reports, maintenance rule records, event reports, and NRC integrated inspection reports for the period of January 2011 through December 2011 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

Inspection Scope

These activities constitute completion of two unplanned transients per 7000 critical hours samples as defined in Inspection Procedure 71151-05.

b.

No findings were identified.

Findings

.4 Unplanned Scrams with Complications (IE04)

a.

The inspectors sampled licensee submittals for the unplanned scrams with complications performance indicator for ANO Unit 1 and Unit 2 for the period from the 1st quarter 2011 through the 4th quarter 2011. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors reviewed the licensees operator narrative logs, issue reports, event reports, and NRC integrated inspection reports for the period of January 2011 through December 2011 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

Inspection Scope

These activities constitute completion of two unplanned scrams with complications samples as defined in Inspection Procedure 71151-05.

b.

No findings were identified.

Findings

.5 Safety System Functional Failures (MS05)

a.

The inspectors sampled licensee submittals for the safety system functional failures performance indicator for ANO Unit 1 and Unit 2 for the period from the 1st quarter 2011 through the 4th quarter 2011. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73." The inspectors reviewed the licensees operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, issue reports, event reports, and NRC integrated inspection reports for the period of January 2011 through December 2011 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

Inspection Scope

These activities constitute completion of two safety system functional failures samples as defined in Inspection Procedure 71151-05.

b.

No findings were identified.

Findings

4OA2 Problem Identification and Resolution

.1 Routine Review of Identification and Resolution of Problems

a.

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.

Inspection Scope

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.

No findings were identified.

Findings

.2 Daily Corrective Action Program Reviews

a.

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.

Inspection Scope

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.

b.

No findings were identified.

Findings

4OA3 Followup of Events and Notices of Enforcement Discretion

.1 (Closed) LER 05000313/2010003 Manual Reactor Scram Conservatively Initiated After

Multiple Abnormal Events Occurred During Plant Startup from a Refueling Outage

On April 18, 2010, Unit 1 was at 11 percent reactor power and preparing to connect the main generator to the electric grid to end refueling outage 1R22. At 1:46 p.m., the operations staff entered the abnormal operating procedure due to indications of a degradation of reactor coolant pump P-32C third stage seal. At 1:56 p.m., an operator at the main turbine reported smoke and small flames at turbine governor valve-3. At 1:57 p.m., control room operators immediately tripped the main turbine and initiated a manual reactor trip in response to the reactor coolant pump seal and the main turbine fire. The manual reactor trip was conservatively performed as neither issue directly required a reactor trip. The licensee determined that the reactor coolant pump seal failure was due to the failure to ensure adequate clearance between the pump coupling slinger ring and the stand pipe splash shield during pump replacement that occurred during the refueling outage. The fire was a result of an electro-hydraulic control fluid spill onto the calcium silicate piping insulation during maintenance. Under the proper conditions, the electro-hydraulic control fluid soaked insulation, heat from the steam lines, and ventilation combined to result in an unexpected exothermic reaction. The licensee implemented corrective actions to revise procedures for reactor coolant pump replacement and provide more supervisory oversight during these infrequent evolutions. The licensee also implemented procedural changes to monitor electro-hydraulic control fluid spills, require specific walkdowns of turbine generator areas following every outage to look for leaks and spills, and to install drip pans under turbine governor and throttle valves to

prevent spills onto the insulation. These issues were placed into the licensees corrective action program as Condition Reports CR-ANO-C-2010-0960, CR-ANO-1-2010-1895, and CR-ANO-1-2010-1896. A self-revealing finding for the reactor coolant pump seal was documented in inspection report 05000313/2010003. This licensee event report is closed.

.2 (Closed) LER 05000368/2009005 Manual Reactor Scram and Emergency Feedwater

Automatic Actuation due to an Unexpected Plant Response Following the Loss of a Main Feedwater Pump at Full Power

On December 08, 2009, Arkansas Nuclear One, Unit 2 was operating near 100 percent reactor power when operators manually tripped main feedwater pump A in response to high thrust bearing temperature. Unit 2 operators entered the loss of main feedwater pump abnormal operating procedure. A manual reactor trip was initiated when the steam generator A water level decreased to approximately 27 percent. The emergency feedwater system automatically actuated as designed to restore steam generator levels.

Operator response was consistent with recent simulator training using the loss of main feedwater pump abnormal operating procedure; however, the ANO Unit 2 simulator response had indicated that steam generator levels could be successfully recovered following the loss of a main feedwater pump without requiring both a reactor trip and emergency feedwater actuation.

The licensee determined that the cause of the event was due to

(1) excessive thrust loading due to feedwater pump internal degradation, and

(2) differences between the actual plant response and the ANO Unit 2 simulator program. Excessive thrust loading was caused by degradation of the main feedwater pump A internals due to contact between the main feedwater pump wear ring and the impeller, which was caused from previous incorrect maintenance. Analysis of the plant transient data revealed differences between the actual plant response and the ANO Unit 2 simulator. The feedwater flow characteristics programmed into the ANO Unit 2 simulator were based on engineering analysis following the ANO Unit 2 power uprate in 2002. Feedwater modifications were implemented and mitigation strategies were changed to maximize available main feedwater flow. Analysis concluded that a slight increase in total feedwater flow would be achieved by those changes. During the event, steam generator levels decreased much faster during the plant transient than previously indicated by the simulator and actual plant main feedwater flows after the loss on a main feedwater pump were less than the original engineering estimates programmed into the simulator.

The licensee took corrective actions to

(1) replace the thrust bearing,

(2) disassemble main feedwater pump, 2P-1A, to determine cause of degradation,

(3) refurbish main feedwater pump, 2P-1A, with a more detailed maintenance procedure,

(4) develop improved performance monitoring program to ensure early detection of thrust bearing degradation and pump performance, and

(5) revise ANO Unit 2 simulator software program to incorporate actual plant data observed from the loss of a main feedwater pump at full power event. The thrust bearing failure issue was placed into the corrective action program as Condition Report CR-ANO-2-2009-3744 and documented as a self revealing finding in Inspection Report 05000368/2010002. The inaccurate simulator

response issue was placed into the corrective action program as Condition Report CR-ANO-2-2009-3768 and documented as a licensee identified violation in the same inspection report. The review of this licensee event report is complete and no findings were identified and no violations of NRC requirements occurred. This licensee event report is closed.

.3 (Closed) LER 05000313/2010001 Multiple Main Steam Safety Valves not within Limits

due to Seat Bonding and Transient-Induced Drift Resulting in a Condition Prohibited by Technical Specifications

On March 18-19, 2010, four main steam safety valves on Unit 1, PSV-2686, 2691, 2697 and 2698 were discovered out of tolerance with respect to technical specification surveillance requirement of + 3 percent pressure lift set point. Unit 1 plant operations were not affected as a result of the failed technical specification surveillance. The licensee determined that there were two issues: two safety valves lifting high out of tolerance and two safety valves lifting low out of tolerance. The licensee determined the cause for the safety valves lifting high out of tolerance was seat binding caused by oxide adhesion layer between metal parts. The licensee determined the cause for the safety valves lifting low out of tolerance was transient-induced drift, which occurs when the spring is exercised due to valve actuations during reactor trips, which occurred during the operating cycle prior to the testing. The licensee has completed corrective action to exercise newly installed safety valves within four months of power operations. These issues were placed into the licensees corrective action program as Condition Report CR-ANO-1-2010-0560. The review of this licensee event report is complete and no findings were identified and no violations of NRC requirements occurred. This licensee event report is closed.

4OA5 Other Activities

.1 (Closed) Temporary Instruction 2515/185 Follow-up on the Industrys Ground Water

Protection Initiative

a. Inspection Scope

The ground water protection program was inspected March 19-22, 2012, to determine whether the licensee had implemented the program elements which were found to be incomplete when previously reviewed during NRC Inspection 05000313/2010004; 05000368/2010004. Inspectors interviewed cognizant licensee personnel and performed walk-downs.

The following elements had been implemented since the previous review:

• Element 1.1.a - Perform hydrogeologic and geologic studies to determine predominant ground water flow characteristics and gradients.

• Element 1.1.c - Identify potential pathways for ground water migration from on-site locations to off-site locations through ground water.

• Element 1.2.a - Identify each structure, system, and component (SSC) and work practice that involves or could reasonably be expected to involve licensed material and for which there is a credible mechanism for the licensed material to reach ground water.

• Element 1.2.b - Identify existing leak detection methods for each SSC and work practice that involves or could involve licensed material and for which there is a credible potential for inadvertent releases to ground water.

• Element 1.2.c - Identify potential enhancements to leak detection systems or programs. These may include additional or increased frequency of rounds or walkdowns or inspections, or integrity testing.

• Element 1.3.a - Using the hydrology and geology studies developed under Objective 1.1, consider placement of ground water monitoring wells down gradient from the plant but within the boundary defined by the site license.

• Element 1.3.b - Consider, as appropriate, placing sentinel wells closer to SSCs that have the highest potential for inadvertent releases that could reach ground water or SSCs where leak detection capability is limited.

• Element 2.2c - When communicating to the State/Local officials, be clear and precise in quantifying the actual release information as it applies to the appropriate regulatory criteria (i.e., put it in perspective) and provide specified information as part of the informal communication.

The following element had not been implemented since the previous review and is documented in the corrective action document listed with the element:

• Element 1.2.d - Identify potential enhancements to prevent spills or leaks from reaching ground water. Licensee personnel acknowledged this element had not yet to be completed, and it was being tracked by Condition Report CR-HQN-2010-00207, Corrective Action 12.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On March 22, 2012, the inspectors presented the results of the radiation safety inspections to Mr. M. Chisum, 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.

On April 12, 2012, the inspectors presented the inspection results to Mr. C. Schwarz, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector 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

S. Baxley, Supervisor,Instrumentation and Controls

S. Bocksnick, Radwaste Technician, Radiation Protection

B. Byford, Manager, Training

D. Calloway, Effluent and Environmental Monitoring Specialist, Chemistry

S. Carey, Supervisor, Instrumentation and Controls

T. Chernivec, Manager, Outages

M. Chisum, Acting Site Vice President / General Manager, Plant Operations

R Clark, Licensing Specialist

R. Crowe, Acting Manager, Security

B. Daiber, Manager, Design Engineering

B. Doehring, Superintendent, Instrumentation and Controls

R. Fuller, Manager, Quality Assurance

W. Greeson, Manager, Engineering Programs and Component

T. Hatfield, System Engineering

R. Holeyfield, Manager, Emergency Preparedness

J. James, Laboratory Technician, Chemistry

K. Jones, Manager, Operations

D. Marvel, Manager, Radiation Protection

J. McCoy, Director, Engineering

S. Morris, Supervisor, Chemistry

N. Mosher, Licensing Specialist

D. Norman, Radwaste Technician, Radiation Protection

B. Pace, Manager, Planning Scheduling, and Outage

D. Perkins, Manager, Maintenance

S. Pyle, Manager, Licensing

T. Rolniak, Specialist, Radiation Protection

C. Schwarz, Site Vice President

R. Sebring, Supervisor, Radiation Protection

T. Sherrill, Manager, Chemistry

R. Starkey, Radwaste Supervisor, Radiation Protection

P. Williams, Manager, System Engineering

NRC Personnel

A. Sanchez, Senior Resident Inspector

J. Rotton, Resident Inspector

W. Schaup, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Opened and Closed

05000313/2012002-01 NCV Failure to Calibrate Unit 1 Effluent and Process Monitors Properly (Section 2RS05)

05000313/2012002-02

05000368 /2012002-02 NCV Failure to Update the Safety Analysis Report with Adequate Details Relative to its Solid Radwaste Equipment, Processes, and Facilities (Section 2RS08)

Closed

05000313/2010003 LER Manual Reactor Scram Conservatively Initiated After Multiple Abnormal Events Occurred During Plant Startup from a Refueling Outage

05000368/2009005 LER Manual Reactor Scram and Emergency Feedwater Automatic Actuation due to an Unexpected Plant Response Following the Loss of a Main Feedwater Pump at Full Power

05000313/2010001 LER Multiple Main Steam Safety Valves not within Limits due to Seat Bonding and Transient-Induced Drift Resulting in a Condition Prohibited by Technical Specifications Temporary Instruction 2515/185 TI Follow-up on the Industrys Ground Water Protection Initiative

Discussed

None