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| [[Issue date::April 30, 2018]]
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| Mr. Richard Site Vice President Entergy Operations, Inc. Arkansas Nuclear One 1448 S.R. 333 Russellville, AR 72802
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| SUBJECT: ARKANSAS NUCLEAR ONE - NRC INTEGRATED INSPECTION REPORT 05000313/2018001 AND 05000368/2018001 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION INSPECTION REPORT 07200013/2017001
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| ==Dear Mr. Anderson:==
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| On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Arkansas Nuclear One facility, Units 1 and 2. On April 5, 2018, the NRC inspectors discussed the results of this inspection with Mr. John Kirkpatrick, General Manager of Plant Operations, and other members of your staff. On April 18, 2018, the NRC inspectors exited to modify the characterization of one finding with Ms. Stephanie Pyle, Regulatory Assurance Manager. The results of this inspection are documented in the enclosed report. NRC inspectors documented two findings of very low safety significance (Green) in this report. Both of these findings involved a violation of NRC requirements. Additionally, NRC inspectors documented a licensee-identified violation, which was determined to be of very low safety significance (Green), in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the violations or significance of the NCVs, 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 Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Arkansas Nuclear One. If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Arkansas Nuclear One. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."
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| Sincerely,/RA/ Neil O'Keefe, Chief Branch E Division of Reactor Projects Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6
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| ===Enclosure:===
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| Inspection Report 05000313/2018001 and 05000368/2018001 and 07200013/2017001 w/
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| ===Attachments:===
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| 1. Documents Reviewed 2. Occupational Radiation Safety Inspection Request for Information Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Numbers: 05000313; 05000368; and 07200013 License Numbers: DPR-51; NPF-6 Report Numbers: 05000313/2018001; 05000368/2018001; and 07200013/2017001 Enterprise Identifier: I-2018-001-0005 Licensee: Entergy Operations, Inc. Facility: Arkansas Nuclear One, Units 1 and 2, and Independent Spent Fuel Storage Installation Location: Junction of Highway 64 West and Highway 333 South Russellville, Arkansas Inspection Dates: January 1, 2018 to March 31, 2018 Inspectors: C. Henderson, Senior Resident Inspector P. Smagacz, Acting Senior Resident Inspector T. Sullivan, Resident Inspector M. Tobin, Resident Inspector L. Brookhart, Senior Inspector N. Greene, Ph.D., Senior Health Physicist J. O'Donnell, CHP, Health Physicist Approved By: N. O'Keefe, Branch Chief 2 SUMMARY The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensee's performance by conducting an integrated inspection at Arkansas Nuclear One, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC's program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC-identified and self-revealed findings and violations, and additional items are summarized in the tables below. A licensee-identified, non-cited violation is documented in report Section 71124.01. List of Findings and Violations Failure to Establish Adequate Criteria for Flood Seal Testing Cornerstone Significance Cross-cutting Aspect Inspection Procedure Mitigating Systems Green Finding NCV 05000313/2018001-01 and 05000368/2018001-01 Closed [H.12] - Avoid Complacency 71111.01 - External Flooding The inspectors identified a Green finding and associated non-cited violation of Unit 1 Technical Specification 5.4.1.a and Unit 2 Technical Specification 6.4.1.a for the licensee's failure to establish the criteria for ensuring the necessary conditions existed for a successful test of hatch flood seals. Specifically, Procedure OP 1402.240, "Inspection of Watertight Hatches," Revision 1, did not contain adequate guidance to ensure that the auxiliary building was at a lower pressure than the turbine building such that puffing smoke on the turbine building side would allow a seal leak to be detectable. Failure to Preplan and Perform Service Water Pre-Screen Maintenance Cornerstone Significance Cross-cutting Aspect Inspection Procedure Mitigating Systems Green Finding NCV 05000368/2018001-02 Closed [H.12] - Avoid Complacency 71152 - Problem Identification and Resolution The inspectors reviewed a self-revealed, non-cited violation and associated finding of Arkansas Nuclear One, Unit 2, Technical Specification 6.4.1.a, for the licensee's failure to properly preplan maintenance that can affect the performance of safety-related equipment. Specifically, the licensee failed to properly preplan pre-screen cleaning maintenance, causing the train B service water system to become inoperable. Additional Tracking Items Type Issue number Title Inspection Procedure Status URI 7200013/2012001-02 Validation of the ANO data collected during the thermal validation test and used in the Holtec analysis 60855.1 Closed 3 Type Issue number Title Inspection Procedure Status URI 7200013/2012001-03 Applicability of the ANO thermal validation test results to other HI-STORM 100 overpack configurations 60855.1 Closed LER 05000313/2016-002-00 Tornado Missile Vulnerability Resulting in Condition Prohibited By Technical Specifications 71153 Closed 4 PLANT STATUS Unit 1 began the inspection period at full power. On March 24, 2018, the unit was shut down to begin Refueling Outage 1R27. Unit 2 began the inspection period at full power. On January 14, 2018, the unit reduced power to 83 percent to perform planned condenser water box cleaning. The unit was returned to rated thermal power on January 19, 2018. INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, "Light-Water Reactor Inspection Program - Operations Phase." The inspectors performed plant status activities described in IMC 2515, Appendix D, "Plant Status," and conducted routine reviews using IP 71152, "Problem Identification and Resolution." The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards. REACTOR SAFETY 71111.01 - Adverse Weather Protection Seasonal Extreme Weather (1 Sample) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures. Unit 1 and Unit 2 diesel fuel oil vault on January 30, 2018 Unit 2 emergency diesel generator 2 on January 30, 2018 Alternate ac diesel generator on January 30, 2018 Unit 1 and Unit 2 emergency cooling pond on January 30, 2018 External Flooding (1 Sample) The inspectors evaluated readiness to cope with external flooding on March 16, 2018. A finding associated with this inspection is documented in the Inspection Results section below.
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| 5 71111.04 - Equipment Alignment Partial Walkdown (4 Samples) The inspectors evaluated system configurations during partial walkdowns of the following systems/trains: (1) Unit 2 train A emergency feedwater system during planned maintenance of train B emergency feedwater system on February 7, 2018 (2) Unit 2 swing service water pump B aligned to the emergency cooling pond during intake structure pre-screen cleaning and maintenance on February 22, 2018 (3) Unit 2 emergency diesel generator 2 ventilation system on March 2, 2018 (4) Unit 1 temporary reactor vessel level identification system on March 28, 2018 Complete Walkdown (1 Sample) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 service water system on March 14, 2018. 71111.05 - Fire Protection Annual/Quarterly Quarterly Inspection (4 Samples) The inspectors evaluated fire protection program implementation in the following selected areas: (1) Unit 2 auxiliary building corridor 2109 temporary safety-related battery heating, Fire Area MM, Fire Zone 2103-V, on January 30, 2018 (2) Unit 1 cable spreading room, Fire Area G, Fire Zone 97-R, on January 31, 2018 (3) Unit 2 upper south piping penetration room, Fire Area EE-L , Fire Zone 2084-DD, on February 8, 2018 (4) Unit 2 lower south piping penetration room, Fire Area EE-L, Fire Zone 2055-JJ, on February 8, 2018 Annual Inspection (1 Sample) The inspectors evaluated fire brigade performance in the Unit 1 control room for a simulated fire emergency feedwater pump room and the Unit 2 turbine deck for a simulated fire in the turbine generator on January 4, 2018, and March 09, 2018.
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| 6 71111.06 - Flood Protection Measures Internal Flooding (1 Sample) The inspectors evaluated internal flooding mitigation protections in the Unit 2 emergency feedwater room floor drain system on March 16, 2018. Cables (1 Sample) The inspectors evaluated cable submergence protection in Manhole 8 on March 1, 2018. 71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification (2 Samples) (1) The inspectors observed and evaluated Unit 1 simulator training for operating crews on reactor shutdown and decay heat removal on February 22, 2018. (2) The inspectors observed and evaluated Unit 2 simulator training for operating crews on reactor coolant pump motor fire and security related events on February 22, 2018. Operator Performance (2 Samples) (1) The inspectors observed and evaluated Unit 2 return to near 100 percent power following condenser cleaning on January 18, 2018. (2) The inspectors observed and evaluated Unit 1 reactor shutdown for commencing Refuel Outage 1R27 on March 23, 2018. 71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness (3 Samples) The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions: (1) Unit 1 rod control system on January 31, 2018 (2) Unit 2 service water system on March 6, 2018 (3) Internal and external flood seals on March 16, 2018 Quality Control (1 Sample) The inspectors evaluated maintenance and quality control activities associated with the following equipment performance issues: (1) Unit 2 control element assembly system on January 31, 2018 71111.13 - Maintenance Risk Assessments and Emergent Work Control (6 Samples) The inspectors evaluated the risk assessments for the following planned and emergent work activities: (1) Unit 2 planned work activities for control element assembly 5 repair on January 5, 2018 7 (2) Unit 2 emergent work activities for emergency diesel generator 2 on January 10, 2018 (3) Unit 2 emergent work activities for service water pump A and C strainer cleaning following high differential pressure alarm during pre-screen cleaning on January 19, 2018 (4) Unit 1 and Unit 2 planned work activities for startup transformer 1 and 3 outage for autotransformer insulator repair on February 2, 2018 (5) Unit 2 planned work activities for service water bay pre-screen cleaning and maintenance on February 22, 2018 (6) Unit 2 service water pre-screen cleaning on February 22, 2018 71111.15 - Operability Determinations and Functionality Assessments (6 Samples) The inspectors evaluated the following operability determinations and functionality assessments: (1) Unit 1 operability determination for auxiliary building tornado missile protection wall missing rebar on January 18, 2018 (2) Unit 1 operability determination for emergency feedwater control valve, CV-2646, stroke time outside operability limits on January 22, 2018 (3) Unit 2 operability determination for emergency diesel generator 2 relay failure and automatic start function for containment coolers on January 24, 2018 (4) Unit 1 and Unit 2 operability determination for emergency cooling pond during cold weather impact of safety-related pumps operating oil temperature on January 31, 2018 (5) Unit 1 and Unit 2 operability determination for 500 kV offsite circuit autotransformer damaged insulator on February 9, 2018 (6) Unit 2 functional determination emergency feedwater system room floor drain system on March 16, 2018 71111.18 - Plant Modifications (2 Samples) The inspectors evaluated the following temporary or permanent modifications: (1) Unit 2 temporary modification for lifting leads for control element assembly 4 for degraded upper gripper coils on January 5, 2018 (2) Unit 2 temporary battery room heating on January 30, 2018 71111.19 - Post Maintenance Testing (4 Samples) The inspectors evaluated the following post maintenance tests: (1) Unit 2 replacement of service water pump A and C strainers on January 20, 2018 8 (2) Unit 1 auxiliary building hatch HTC-492 smoke testing following resin transfer on February 14, 2018 (3) Unit 2 motor driven emergency feedwater pump flow transmitter calibration due to the transmitter reading low out of range on February 20, 2018 (4) Unit 1 temporary reactor vessel level indication due valve, RC-1, repair on March 28, 2018 71111.20 - Refueling and Other Outage Activities (Partial Sample) The inspectors evaluated Unit 1 Refueling Outage 1R27 activities from March 24, 2018, to March 31, 2018. The inspectors completed inspection procedure Sections 03.01.a and 03.01.c. 71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Routine (3 Samples) (1) Unit 1 emergency feedwater solenoid operated control valve, CV-2646, establishment of stroke time reference value and acceptance criteria on January 25, 2018 (2) Unit 1 and Unit 2 verified correct breaker alignment and indicated power availability for the 161 kV offsite circuited with the 500 kV offsite inoperable during autotransformer insulator repair on February 2, 2018 (3) Unit 1 train A reactor protection system and rod control system ac breaker surveillance trip testing on February 27, 2018 In-service (1 Sample) (1) Unit 2 service water motor operated valve, 2CV-1435-1, service water inlet to train A shutdown heat exchanger on March 15, 2018 Reactor Coolant System Leak Detection (1 Sample) (1) Unit 1 small increase of unidentified leakage on March 2, 2018 RADIATION SAFETY 71124.01 - Radiological Hazard Assessment and Exposure Controls Radiological Hazard Assessment (1 Sample) The inspectors evaluated radiological hazards assessments and controls. Instructions to Workers (1 Sample) The inspectors evaluated worker instructions.
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| 9 Contamination and Radioactive Material Control (1 Sample) The inspectors evaluated contamination and radioactive material controls. Radiological Hazards Control and Work Coverage (1 Sample) The inspectors evaluated radiological hazards control and work coverage. High Radiation Area and Very High Radiation Area Controls (1 Sample) The inspectors evaluated risk-significant high radiation area and very high radiation area controls. Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample) The inspectors evaluated radiation worker performance and radiation protection technician proficiency. 71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls Implementation of ALARA and Radiological Work Controls (1 Sample) The inspectors reviewed ALARA practices and radiological work controls by reviewing the following activities and/or work packages: (1) 2017-1070, core bore National Fire Protection Association (NFPA) 805 project and support activities (2) 2018-1414, as low as reasonable achievable (ALARA) activities during 1R27 (3) 2018-1420, scaffold installation/removal non-Locked High Radiation Areas - 1R27 (4) 2018-1430, reactor disassembly, reassembly, and support activities (5) 2018-1900, emergent maintenance activities during 1R27 Radiation Worker Performance (1 Sample) The inspectors evaluated radiation worker and radiation protection technician performance. OTHER ACTIVITIES - BASELINE 71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below: (8 Samples) (1) IE01: Unplanned Scrams per 7000 Critical Hours Sample, Unit 1 and Unit 2, (January 1, 2017, through December 31, 2017) (2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample, Unit 1 and Unit 2, (January 1, 2017, through December 31, 2017)
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| 10 (3) IE04: Unplanned Scrams with Complications Sample, Unit 1 and Unit 2, (January 1, 2017, through December 31, 2017) (4) OR01: Occupational Exposure Control Effectiveness Sample (April 1, 2017, through March 30, 2018) (5) PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual (RETS/ODCM) Radiological Effluent Occurrences Sample (April 1, 2017, through March 30, 2018) 71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (1 Sample) The inspectors reviewed the licensee's implementation of its corrective action program related to the following issues: (1) Unit 2 train B service water inoperable due to strainer high differential pressure during pre-screen cleaning following winter shad run on March 27, 2018 A finding associated with this inspection is documented in the Inspection Results section below. 71153 - Follow-up of Events and Notices of Enforcement Discretion Events (2 Samples) (1) The inspectors evaluated licensee's response to Unit 2 entry into loss of service water abnormal operating procedure due to service water pump A and C strainer high differential pressure alarm during pre-screen cleaning on January 19, 2018. (2) The inspectors evaluated licensee's response to Unit 1 and Unit 2 cyber security issues on the business network on February 6, 2018. Licensee Event Reports (LERs) (1 Sample) The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx: (1) LER 05000313/2016-002-00, Tornado Missile Vulnerability Resulting in Condition Prohibited By Technical Specifications, on February 5, 2018 OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants The inspectors evaluated the licensee's operation of the independent spent fuel storage installation (ISFSI) from October 30 to November 2, 2017, on-site at ANO, and conducted an in-office review of additional documentation related to licensee's maintenance of their cask handling crane until January 2018.
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| 11 The ANO ISFSI consisted of four ISFSI pads. ANO had loaded 24 canisters of the Energy Solutions ventilated storage cask (VSC) VSC-24 design (Certificate of Compliance No. 1007) from 1996 to 2003. Since that time, ANO had been loading HI-STORM 100S Version C overpacks. ANO's ISFSI contained a total of 57 HI-STORM overpacks with 32 MPC-24 canisters and 25 MPC-32 canisters, at the time of the routine inspection. ANO was currently loading canisters to the Holtec Certificate of Compliance 1014, Amendment 5, and Final Safety Analysis Report (FSAR), Revision 7. The ISFSI activities specifically reviewed during the on-site inspection and the subsequent in-office review included: (1) Evaluated and observed fuel selection and fuel loading operations. (2) Reviewed the licensee's loading, processing, and heavy load procedures associated with their current dry fuel storage campaign. (3) Reviewed licensee's corrective action program implementation for ISFSI operations since the last routine ISFSI inspection which was completed in December 2015. (4) Reviewed quality assurance (QA) program implementation, including recent QA audits, surveillances, receipt inspection, and quality control activities. (5) Reviewed documentation related to technical specification (TS) required operational surveillance activities and Final Safety Analysis Report (FSAR) required annual maintenance activities. (6) Reviewed the licensee's radiological monitoring data for the calendar years 2014, 2015, and 2016. (7) Reviewed spent fuel documentation for the canisters loaded since the last routine ISFSI inspection (Holtec Canister 48-57) to confirm the fuel met all TS requirements for storage and transportation. (8) Reviewed annual maintenance activities for heavy lifting components which included special lifting devices and the site's cask handling crane (Auxiliary Building L-3 crane). (9) Reviewed all 72.48 safety evaluations/screenings for changes made to the licensee's ISFSI operations in accordance with Inspection Procedure 60857 since the last routine ISFSI inspection. (10) Reviewed all changes made to the licensee's 72.212 Report (Revision 10) in accordance with Inspection Procedure 60856.1 since the last routine ISFSI inspection. Additionally, inspectors closed two unresolved items (URIs) from a routine ISFSI inspection conducted in 2012 (see Inspection Results).
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| 12 INSPECTION RESULTS Failure to Establish Adequate Criteria for Flood Seal Testing Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000313/2018001-01 and 05000368/2018001-01 Closed [H.1] - Resources 71111.01 - External Flooding The inspectors identified a Green finding and associated non-cited violation of Unit 1 Technical Specification 5.4.1.a and Unit 2 Technical Specification 6.4.1.a for the licensee's failure to establish the criteria for ensuring the necessary conditions existed for a successful test of hatch flood seals. Specifically, Procedure OP 1402.240, "Inspection of Watertight Hatches," Revision 01, did not contain adequate guidance to ensure that the auxiliary building was at a lower pressure than the turbine building such that puffing smoke on the turbine building side would allow a seal leak to be detectable. Description: As part of corrective actions to prevent recurrence for Yellow finding 05000313/2014009-01 and 05000368/2014009-01, the licensee improved the preventive maintenance for flood seals on hatches that prevented flood waters from external sources from entering the auxiliary building, where safety-related accident mitigation equipment was located. These actions included a new testing protocol which established a pressure differential across the seal, then puffed chemical smoke around the seal and observed for leaks. Known as a smoke test, this method requires that air pressure inside the auxiliary building be lower than turbine building air pressure so that when smoke is puffed around the outside of the seal, the smoke would be pulled into the lower pressure area on the other side, and leaks would be detectable. On November 29, 2017, as part of a Confirmatory Action Letter Inspection, NRC inspectors reviewed corrective actions and observed a smoke test of hatch 492. The inspector noted that test personnel had checked that the auxiliary building ventilation was in a normal alignment, but had assumed that this meant that pressure was lower on the auxiliary building side of the hatch. When the licensee agreed to measure the pressure on each side of the hatch, pressure was actually higher on the auxiliary building side such that leakage would not have been detectable. Procedure OP 1402.240, "Inspection of Watertight Hatches," Revision 01, directed personnel to ensure negative ventilation in the auxiliary building prior to start. However, the procedure did not state how much pressure differential was needed or how this was to be measured. The inspector determined that all six hatches that serve as flood barriers were previously tested using the inadequate procedure. Upon discovery, the licensee took action to ensure that a negative ventilation in the auxiliary building would be established and verified as part of the procedure. When re-tested, all hatches passed the smoke test. Corrective Action(s): The corrective action was to make changes to the procedure to establish appropriate ventilation lineup and re-perform the smoke tests at all locations. Corrective Action Reference(s): Condition Report CR-ANO-C-2017-04759 13 Performance Assessment: Performance Deficiency: The licensee's failure to establish adequate prerequisite criteria for smoke testing flood seals on hatches is a performance deficiency. Screening: The performance deficiency is more than minor because, if left uncorrected, it has the potential to become a more significant safety concern. Specifically, because Procedure OP 1402.240 did not have adequate instructions to ensure the appropriate ventilation lineup, hatch flood seals would always pass the test regardless of whether the seal would allow water to pass or not. Therefore, any flooding or pipe rupture could lead to water ingress into the Unit 1 and Unit 2 auxiliary buildings affecting the availability of mitigating equipment needed to respond to flooding. This finding affects the Mitigating Systems Cornerstone. Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) for Findings At-Power," dated June 19, 2012. The inspectors determined that the finding had very low safety significance (Green) because the equipment or safety function was not completely failed or unavailable, and because the finding does not involve the total loss of any safety function, identified by the licensee through a probabilistic risk assessment (PRA), individual plant examination of external events (IPEEE), or similar analysis, that contributes to external event initiated core damage accident sequences. Specifically, since the hatches were confirmed to be leak tight after re-testing, no actual loss of function occurred. Cross-cutting Aspect: This finding has a cross-cutting aspect in the area of human performance associated with avoiding complacency, because the individuals failed to verify that procedure prerequisites were met rather than assume they are met based on general plant conditions. Enforcement: Violation: Technical Specification 5.4.1.a for Unit 1 and Technical Specification 6.4.1.a for Unit 2 requires, in part, that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix A to Regulatory Guide 1.33, "Quality Assurance Program Requirements," Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 9.a, states that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Contrary to the above, on November 29, 2017, the licensee failed to properly preplan and perform maintenance that can affect the performance of safety-related equipment in accordance with written procedures, document instructions, or drawings appropriate to the circumstances. Specifically, Procedure 1402.240, "Inspection of Watertight Hatches," Revision 01, failed to include adequate details needed to not verify that the auxiliary building was at a lower pressure than the turbine building prior to performing a smoke test of the flood seal of hatch 492. Under the existing conditions, the test would have passed even with a degraded seal. This condition had the potential to affect the performance of safety-related mitigating equipment needed to respond to a flooding event.
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| 14 Disposition: This violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy, because it was very low safety significance (Green) and was entered into the licensee's corrective action program as Condition Report CR-ANO-C-2017-04759. Failure to Preplan and Perform Service Water Pre-Screen Maintenance Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000368/2018001-02 Closed [H.12] - Avoid Complacency 71152 - Annual Follow-up of Selected Issues The inspectors reviewed a self-revealed, non-cited violation and associated finding of Arkansas Nuclear One, Unit 2, Technical Specification 6.4.1.a, for the licensee's failure to properly preplan maintenance that can affect the performance of safety-related equipment. Specifically, the licensee failed to properly preplan pre-screen cleaning maintenance, causing the train B service water system to become inoperable. Description: On January 19, 2018, ANO Unit 2 was operating in Mode 1 and making preparations to clean the intake structure service water pre-screens in accordance with Operating Procedure (OP) 2104.029, "Service Water System Operations," Change 109. Two operable trains of service water are required per Unit 2 Technical Specification 3.7.3.1, Service Water System while in Mode 1. The ANO Unit 2 service water system has stationary pre-screens between the traveling screens and the pumps that must be manually hoisted out of the flow stream to be cleaned. The configuration is such that debris can be knocked loose and fall back into the flow stream during cleaning and enter both running pumps. The pre-screens are intended to catch small debris that was not removed by the traveling screen so that the strainer baskets located downstream of each pump do not get clogged. The discharge strainer basket design does not have a self-cleaning feature. Between January 16, 2018, through dayshift January 18, 2018, the licensee was aware that they were experiencing a shad (fish) run in the intake canal. The pre-screen differential pressure (D/P) had been exhibiting a rising trend due to debris buildup. During this timeframe, the pre-screen and traveling screen D/P went from 3.00 inches of water to 6.75 inches of water. At 8:52 pm on January 18, 2018, the licensee received the service water high differential pressure alarm and pre-screen D/P was 9.5 inches of water, with a procedural requirement to initiate action to clean the pre-screens at 8 inches of water. Prior to the licensee cleaning the pre-screens, D/P reached 18 inches of water. This rate of debris buildup was unusual considering most D/P effects on the screen are witnessed on ANO Unit 1 screens and not ANO Unit 2 screens. Based on past experience of slow build-up of debris, the licensee delayed pre-screen cleaning until 4:14 a.m. on January 19, 2018, to avoid having maintenance personnel exceed fatigue management limits. During the lifting and removal of the first pre-screen for cleaning, fish were observed to be falling off and entering the suction of the A (SW-P-A) and C (SW-P-C) service water pumps. As a result, the Unit 2 control room received SW-P-A and SW-P-C discharge strainer high differential pressure (D/P) annunciators. The SW-P-A discharge strainer D/P peaked at 12.8 psid, and the SW-P-C discharge strainer D/P peaked at 24.1 psid. The licensee entered 15 abnormal Operating Procedure 2203.022, "Loss of Service Water," Revision 14, and assessed the operability of train A and B service water systems. The swing pump suction was aligned to the emergency cooling pond and the pump started so that a second train of service water could be made available if needed. Following an engineering evaluation, train B service water system was declared inoperable due to exceeding the 20 psid operability limit for the SW-P-C strainer; train A service water system remained operable throughout the event. Over the course of the rest of the day, the licensee manipulated the service water system to clean the rest of the pre-screens and the service water pump discharge strainers and reestablish train B service water system operability. The train B service water system was declared operable at 10:10 p.m. on January 19, 2018, at which time the "Loss of Service Water" procedure was exited. The licensee's short term corrective action was to implement a standing order for service water pre-screens and traveling screens that required operations personnel to log both pre-screen and traveling screen D/P and clean traveling screens at least weekly and pre-screens weekly. The licensee documented this issue in Condition Report CR-ANO-C-2018-00299. The inspectors noted that a similar event occurred on August 19, 2016. The D/P on the train B service water pump strainer continued to rise until it reached the threshold at which the performance of an engineering evaluation was required to determine the operability of the B train of service water. This high D/P was attributed to fouling of the strainer caused by pre-screen cleaning activities and delaying the start of the cleaning. Despite this event, the same basic chain of events recurred on January 19, 2018. The inspectors pointed out that the pre-screen design created an inherent risk of spilling debris into the open hole created by lifting the pre-screens. With both trains in a normal alignment, most of the debris would enter both pumps and begin to clog the discharge strainer. The inspectors questioned why this risk was not avoided by proactively aligning one or both trains to the emergency cooling pond. The licensee agreed to study this alternative as a possible corrective action. Corrective Action(s): The immediate corrective action was to restore operability of the train B service water system and institute a weekly pre-screen cleaning regiment. Corrective Action Reference(s): Condition Report CR-ANO-C-2018-00299 Performance Assessment: Performance Deficiency: The licensee's failure to properly preplan pre-screen cleaning maintenance that can affect the performance of safety-related equipment is a performance deficiency. As a result, the performance of both trains of the safety-related service water system were challenged, and train B was rendered inoperable. Screening: The performance deficiency was more than minor because it adversely affected the human performance attribute of the Mitigating Systems Cornerstone and the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee's failure to properly preplan pre-screen cleaning maintenance resulted in the train B service water system being rendered inoperable. Significance: Using NRC Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) for Findings At-Power," dated June 19, 2012, Exhibit 2, "Mitigating Systems Screening Questions," the inspectors determined that the finding had very low safety significance (Green) because it: was not a design deficiency; did not 16 represent a loss of system and/or function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety-significant, nontechnical specification train. Cross-cutting Aspect: The finding had a cross-cutting aspect in the area of human performance associated with avoid complacency because the licensee did not plan for the inherent risk with cleaning the pre-screens although cleaning of debris has previously challenged the service water system. Specifically, the licensee did not effectively plan pre-screen cleaning maintenance to avoid system impacts, and did not consider the rate of increase in pre-screen differential pressure due to the winter fish runs in deciding when to start the cleaning. Enforcement: Violation: Technical Specification 6.4.1.a requires, in part, that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 9.a of Regulatory Guide 1.33, Appendix A, states that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Contrary to the above, on January 19, 2018, the licensee failed to properly preplan and perform maintenance as prescribed in Regulatory Guide 1.33. Specifically, the licensee failed to preplan the cleaning of Unit 2 service water pre-screens prior to high debris loading of the screens, and failed to place the service water system into an alignment that would have avoided impacting the operability of this safety-related system. Disposition: This violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy, because it was very low safety significance (Green) and was entered into the licensee's corrective action program as Condition Report CR-ANO-C-2018-00299. Licensee Identified Non-Cited Violation 71124.01 -Radiological Hazard Assessment and Exposure Controls This violation of very low safety significant (Green) was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy. Violation: Title 10 CFR 20.1501(a) requires that each licensee make or cause to be made surveys that may be necessary for the licensee to comply with the regulations in 10 CFR Part 20, and that are reasonable under the circumstances to evaluate the magnitude and extent of radiation levels, concentrations, or quantities of radioactive materials, and the potential radiological hazards that could be present. Contrary to the above, on August 7, 2017, the licensee failed to make necessary surveys of the Unit 2, 2T-15 tank room, that were reasonable to evaluate the magnitude and extent of radiation levels that could be present. Consequently, workers were allowed access to an area with dose rates up to 1000 millirem per hour at 30 cm without a proper briefing or oversight.
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| 17 Significance: Using NRC Manual Chapter 0609, Appendix C, "Occupational Radiation Safety Significance Determination Process," the inspectors determined the finding to be of very low safety significance (Green) because: (1) it was not associated with as low as is reasonably achievable (ALARA) planning or work controls; (2) there was no overexposure; (3) there was no substantial potential for an overexposure; and (4) the ability to assess dose was not compromised. Corrective Action Reference(s): CR-ANO-2-2017-04634 and CR-ANO-2-2017-05337 Unresolved Item (Closed) Validation of the ANO data collected during the thermal validation test and used in the Holtec analysis. URI 7200013/2012001-02 60855.1 Description: During the routine ISFSI inspection conducted on October 29 - November 1, 2012, an unresolved item (URI) was identified and documented in the routine ISFSI NRC Inspection Report 05000313/20120008, 05000368/2012008, and 07200013/2012001 (ADAMS Accession No. ML13057A986). The Holtec International HI-STORM 100 Certificate of Compliance (CoC) No. 1014, Condition 9, required the performance of a one-time thermal validation test on the first cask that exceeded 20 kW to validate the analytical methods and thermal performance predicted by the licensing basis thermal model as described in Chapter 4 of the Holtec HI-STORM 100 FSAR. ANO was the first general licensee to load a canister exceeding 20 kW and, as such, was required to perform the thermal validation test in accordance with License Condition 9. During the NRC inspection in 2012, the inspectors identified that ANO had completed the test using instrumentation that had not been controlled or calibrated in accordance with ANO's quality assurance program. The NRC identified this failure to follow the ANO's quality assurance program for the thermal validation test instrumentation as a non-cited violation of 10 CFR 72.164 (NCV 07200013/2012001-01) consistent with Section 2.3.2 of the NRC Enforcement Policy. The validation of the data collected by the instrumentation used during the test was considered indeterminate until the licensee was able to demonstrate that the equipment was properly calibrated by a qualified vender on the licensee's approved vendor list. The resolution of this issue was tracked as an unresolved item (URI 07200013/2012001-02). ANO took corrective actions to verify that the data from the measuring instruments was acceptable by sending the equipment to a qualified lab to verify the equipment was properly calibrated. ANO was able to verify the calibration of the resistance temperature detectors used in the test. The other equipment used in the test were DANTEC LVFA wind tunnel 435-1010 anemometer probes which measured air velocities at very low rates of speed. ANO sent these anemometers to multiple labs including Exelon Labs and National Aeronautics and Space Administration (NASA) for calibration. Unfortunately, none of the labs were able to successfully test the equipment to verify they were properly calibrated, and upon return to ANO, the anemometers were broken in transit. ANO was unable to verify the validity of the data collected during their thermal validation test. Corrective Action Reference(s): CR-ANO-C-2013-00374, CR-ANO-C-2013-0575, and CR-ANO-C-2013-00576 Closure Basis: Since the ANO staff were unable to validate the data collected for the thermal validation test, as required by CoC License Condition 9, the required test will still need to be 18 performed. However, the NRC has concluded that the wording from CoC License Condition 9 (Amendments 5-9) was not suitable to provide adequate test data to confirm the Holtec thermal analysis as described in the FSAR. The License Condition 9 required measuring air velocity within the annulus area between the canister and the overpack. The data provided in the ANO test was inconsistent and the test requirements listed in the CoC Amendments 5 through 9, License Condition 9, needed to be revised to provide more consistent data that could be utilized by the vendor and the NRC to verify the analytical models from the FSAR. On May 31, 2016, NRC issued CoC 1014, License Amendment 10, (ADAMS Accession No. ML17237B994) which modified the License Condition 9 thermal validation test to measure air velocity at the inlet vents and not the annulus area between the canister and the overpack. The first general licensee to load a canister that exceeds 20 kW, under CoC 1014 License Amendment 10, is required to perform the thermal validation test using the new method as described in the license condition. This test will provide sufficient data for the vendor to perform the required analysis and allow the NRC more stable results to review and conclude on the validation of the thermal model as described in the FSAR. A licensee in another region has described their intention of performing the required thermal validation test in the 2018 timeframe. Unresolved Item (Closed) Applicability of the ANO thermal validation test results to other HI-STORM 100 overpack configurations. URI 07200013/2012001-03 60855.1 Description: On February 3, 2012, Entergy submitted a letter to the NRC informing the agency of the completion of the thermal validation test (discussed above) and the completion of the Holtec analysis (ADAMS Accession No. ML12038A177). On September 14, 2012, Holtec also informed the NRC of the completion of the ANO thermal validation test and provided a copy of Holtec Report HI-2114925 (ADAMS Accession No. ML12264A541) which evaluated the test data. The Holtec report indicated that the thermal model utilized in the licensing-based analysis methodology had predicted an air mass flow rate lower than the values measured in the ANO thermal test and, as such, demonstrated an overall conservatism of the licensing-based methodology, thereby confirming the suitability of the methodology for demonstrating the thermal-hydraulics safety of the HI-STORM 100 cask system and satisfying the requirement of Condition 9. Holtec issued a statement to the other HI-STORM 100 general licensee users concerning the ANO test on a HI-STORM 100S, Version C, overpack and whether the results could be applied to other cask models of the 100 series. Holtec Licensing Position Paper HL-2011-01 was distributed to Holtec cask users dated August 5, 2011. Holtec concluded that the ANO test data demonstrated the validity of the thermal models, and as such, the results of the ANO test could be applied to any of the HI-STORM 100 overpack configurations. During a meeting on December 18, 2012, between the NRC, ANO, and Holtec, the applicability of the ANO test to the other HI-STORM overpacks was discussed extensively. A number of questions remained as to the sensitivity of the test results to the various configurations of the overpack dimensions and vent sizes. As such, the NRC needed to perform an independent evaluation to confirm Holtec's position. The independent review performed by the NRC was tracked as an unresolved item (URI 07200013/2012001-03). Corrective Action Reference(s): CR-ANO-C-2013-00374, CR-ANO-C-2013-0575, and CR-ANO-C-2013-00576 19 Closure Basis: As described above in URI 07200013/2012001-01, the NRC concluded that the wording from CoC License Condition 9 (Amendments 5-9) was not suitable to provide adequate test data to confirm Holtec's thermal methodology. On May 31, 2016, NRC issued CoC 1014 License Amendment 10 (ADAMS Accession No. ML17237B994), which modified the License Condition 9 thermal validation test to measure air velocity at the inlets and not the annulus area between the canister and the overpack. The first general licensee to load a canister that exceeds 20 kW under CoC 1014 License Amendment 10, is required to perform the thermal validation test using the new method as described in the License Condition. Once the new data is collected and analyzed by the general licensee and the vendor, the information will be submitted to the NRC for an independent review. A general licensee in another region has described their intention of performing the required thermal validation test in the 2018 timeframe.
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| 20 EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report. On January 18, 2018, the inspector presented the results from the routine ISFSI inspection to Ms. S. Pyle, Licensing Manager, and other members of the licensee staff. On March 30, 2018, the inspector presented the radiation protection inspection results to M
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