IR 05000313/1997013

Ack Receipt of 970728,0825 & 0930 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-313/97-13 & 50-368/97-13

ML20217K859
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/22/1997
From:	Powers D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Hutchinson C ENTERGY OPERATIONS, INC.
References
50-313-97-13, 50-368-97-13, GL-89-04, GL-89-4, NUDOCS 9710300053
Download: ML20217K859 (4)

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[ AH LINGToN, T E X AC 76011 8064 October 22, 1997 C. Randy Hutchinson, Vice President Operations Arkansas Nuc!oor One Entergy Operations, Inc.

1448 S.R. 333 Russellville, Arkansas 72801 0967 SUBJECT: NRC INSPECTION REPORT 50-313/9713; 50 368/9713 AND NOTICE OF VIOLATION AND NOTICE OF DEVIATION

Dear Mr. Hutchinson:

'ihank you for your letters of July 28, August 25, and September 30,1997, in response to our letter, Notice of Violation, and Notice of Deviation dated June 28,1997, and telephone call on August 21,1997.

Your letter dated September 30,1997, provided an acceptable change to your response contained in your letter dated August 25, 1997.- Specifically, your August 25,1997, letter stated that you would test Arkansas Nuclear One Check Valves BW-4A, BW 48, CA 61, CA 62, BW 2, and BW 3 under a work plan to meet the quarterly testing frequency and

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that permanent test procedures would be developed and implemented by September 30,

-1997. Your letter dated September 30,-.1997, stated that all valves _ were tested satisfactorily, test procedures developed, and quarterly testing scheduled, except for Sodium Hydroxide Tank Outlet Check Valves CA-61 and CA 62. You determined that system :onfiguration did not allow for reliable and repeatable quarterly testing of their functional capability. Per the provisions of Generic Letter 89 04, " Guidance on Developing Acceptable inservice Testing Programs," you have chosen to disassemble, inspect, and manually stroke these valves during alternate refueling outages, and have revised your inservice test program and inservice Test Program Bases Document to reflect this change.

It is our understanding that all other valves identified in the Notice of Violation have been appropriately tested and found to be acceptable. Please inform us if our understanding is /

not correct. i

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We will review the implementation of your corrective actions duiing a future inspection to determine that full compliance has been achieved and will be maintained.

Sincerely, 9710300053 97 2R " #

PDR ADOCK 0 313 Dr. Dalt A. Powers, Chief G POR Maintenance Branch Division of Reactor Safety Docket Nos.: 50 313;50-368 License Nos.: OPR-51; NPF 6 llllll '

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[ Entergy Operations, Inc. 2-cc:

Executive Vice President

& Chief Operating Officer Entergy Operations, Inc.

P.O. Box 31995 Jackson, Mississippi 39286 1995 Vice President Operations Support Entergy Operations, Inc.

P.O. Box 31995 Jackson, Mississippi 39286 Manager, Washington Nuclear Operations ABB Combustion E' ,'~ ring Nuclear Power 12300 Twinbrook Parkway, Suite 330 Rockville, Maryland 20852 County Judge of Pope County Pope County Courthouse Russellville, Arkansas 72801 Winston & Strawn 1400 L Street, N.W.

Washington, D.C. 20005 3502 David D. Snellings, Jr., Director -

Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street, Mail Sbt 30 Little Rock, Aikansas 72205 3867 Manager Rockville Nuclear Licensing Framatome Technologies 1700 Rockville Pike, Suite 525 Rockville, Maryland 20852

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Entergy Operations, Inc. 3-Distribution w/conv of licensee's letters dated Julv 28. Auount 25. and Sootember 30.1997

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DCD (IE01) l Regional Administrator Resident inspector DRP Director MIS System Branch Chief (DRP/C) RIV File Project Engineer (DRP/C) DRS PSB Branch Chlef (DRP\TSS) D/DRS DD/DHS LEEllershaw, DRS/MB l-l

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l DOCUMENT NAME: G:\ REPORTS \AN713AK. LEE Al 97 G 0076 To receive copy of document. Indicate in box:"Cae Copy without enclosures *E" * Copy with enclosures *N" * No copy RIV:MB l. f.. C:DRS/MB -

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100//97 10/8/97 OFFICIAL RECORD COPY n

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Entergy Operations, Inc. -3-DIEltibullDn.YdcDRY_011ictuitE11c11cIlduled_ July _2BJtuust 25. and statember 30m1D31; DCD (IE01)

Re0i onal Administrator Resident inspector DRP Director Mis System Branch Chief (DRP/C) RIV File Project Engineer (DRP/C) DRS PSB Branch Chief (DRP\TSS) D/DRS DD/DRS LEEllershaw, DRS/MB DOCUMENT NAME: G:\ REPORTS \AN713AK. LEE Al 97-G 0076 To receive copy of document. :ndicate in box: *C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:MB l e.,. C:DRS/MB

,LEEllershawidiE- DAPowers df 100//97 10//V97 OFFICIAL RECORD COPY

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10CFR2.201 i

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July 28,1997

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OCAN079709 O U. S. Nuclear Regulatory Commission ' '

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Document Control Desk / '

Mail Station Pl.137 Washington, DC 20555 g,,/(g eh zGio',n Subject: Arkansas Nuclear One Docket Nos. 50 313 and 50-368

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License Nos. DPR.51 and NPF 6 Response to Inspection Report 50 313/97-13;50 36&l97 13 '

Gentlemen:

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L Pursuant to the provisions of 10CFR2.201, attached is the response to the notice of violation identified during the inspection activities associated with the.Inse.vice Testing Program and the response to the notice of deviation identified during the inspection activities associated with conunitments to perform radlugraphic and ultrasonic examinations.

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Should you have questions or comments, please call me at 501-858-4601.

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Very truly yours, d'*" C 77/,,,1 Dwight C. Mims Director, Nuclear Safet)

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DCM/RMC Attachments

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00AN079709 Page 2

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Mr. Ellis W. Merschoff Regional Administrator U. S. Nuclear Regulatory Commission RegionIV j 611 Ryan Plaza Drive, Suite 400 *

. Arlington, TX 760118064

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NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London,AR72847 Mr. George Kalman-NRR Project Manager Region IV/ANO.1 & 2 *

U. S. Nuclear Regulatory Commission NRR Mail Stop 13113 One White Flint North 11555 Rockville Pike Rockville, MD 20852

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OCAN079709

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NOTICE OF VIOLATION l

During an NRC inspection conducted on May 12 through June 5,1997, one violation of NRC requhements was identified. Ia accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violation is listed below:

10 CFR 50.55a(f) requires inservice tests to verify the operational readiness of pumps and valves, whose function it required for safety, to comply with the requirements ret forth in Section XI of the appropriate edition and addenda of the AShiE Boiler and i'ressure Vessel Code.

Article IWV-Il00 of the ASME Code provides the rules and requirements for

'nse:vice testing to assess operational readiness of certain ASME Cooe Class 1,2,

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aad 3, valves which are required to perform a specific function in shutting down a reactor to the cold shutdown condition or in mitigating the consequences of an accident.

Article IWV 3000 in Section XI of the ASME Code specifici, the type of tests to be peiformed on each category of valve, and Subarticle IWV-3412(a) states that valves are to be exercised to the position reauired to fulfill their fbnction (i.e., open or closed).

Contrary to the above, the following conditions were identified:

1. Seven Unit 2 ASME Code valves, which had a safety fbnetion to opa and were reqaired to be tested in accordance with Section XI of the ASME Code, were not included in the insenice test program. The normally closed Category B valves were located la the service water piping which provides makeup water to 'he spent fuel, snd were identified as 2FP-31; 2FP-46; 2SW-56; 2SW 5 ,2SW-62; 2SW 67; and 2SW-138.

2. Eight ASME Lode vah es (six in Unit I and two in Unit 2) that were in the

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insenice test program, were not being tested or exercised to verify their abliity to fulfill their closed safety function. The Unit I valves were identified as: BW-4A/4B (Borated Water Storage Tank Outlet Check Valves); CA-61/62 (Sodium Hydroxide Storage Tank Outlet Check Valves), and BW-2/3 (High Pressure Injection Pump- Suction Check Valves). The Unit 2 valves were identified os: 2BS-1AliB (Refueling Water fank Outlet Check Valves).

This is a Severity Level IV violation (Supplement 1)(50-313;-368/9713-01).

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I Resnonne to Notice of Violation 50 313: Si 3/9713 01 l*

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(1) Reason for the violation:

On May 19,1997, the inspector noted that the Unit 1 Borsted Water Storage Tank -

(BWST) Outlet Check Valves BW-4A and BW-4B were included in the inservice test (IST) program; however, they were identified as having an open safety function only. These valves are the first isolation valves, of dual isolation valves, in paths from the emergency core cooling system (ECCS). Since these valves were not identified as having a closed safety function, they were not being tested in the closed position. ANO 2 check valves 2BS 1 A and 2BS 1B, ANO-2 Refbeling Wster Tank (RWT) Outlet Check Valves were similarly identified.

In response, a condition report was initiated. The condition report noted that prior to 1993, IST testing of BW 4A and BW-4B consisted of valve disassembly and manually moving the valve disk to the open and closed position per approved relief requests. Additionally, four other ANO 1 valves were identified u not having a closed safety fbnction, yet were considered to be part of a dual isolation configuration (CA-61, CA 62 Sodium Hydroxide Tank Outlet Check Valves and BW-2, BW 3 - High Pressure Injection Pump Suction Check Valves). Another condition report action was initiated to determine if a similar condition existed on ANO 2. As a result of fbrther review, seven additional ANO-2 ASME Code, safety related, normally closed valves that have an open safety fbnction, but were not in the IST program, were identified. The identified valves were 2FP 31, 2FP-46,2SW-138,2SW-56,2SW 57,2SW-62, and 2SW-67, all Category B valves in the service water piping which provide makeup water to the spent fbel pool.

These valves, except those providing service water make.up to the spent fbel pool, were previously identified for inclusion in the IST program. In the fall of 1996, an independent review of the ' ANO-1 and ANO 2 IST basis documents was performed. One of the observatiom, made during the review was that ANO 1 valvea. BW-2, BW-3, BW-4A, BW-4B, CA-61, and CA-62, had a closed safety fbnction. A procedure improvement form was provided to ANO-1 Operations to inform them that the subject valves had a closed function and test procedures

, needed to be developed. Additionally, another observation fkom the review identified ANO 2 valves,2BS 1A and 2BS 1B as having a closed fbnction and discussions with ANO 2 Operations were ongoing.

The root cause of 2BS 1 A,2BS 1B, BW 2, BW-3, BW-4A, BW-4B, CA-61, and CA 62 not being reverse flow tested in the IST program was the failure to recognize the closed safety function'that these vah es perform, i.e., the second of two valves need to complete a closed system. The root cause of the seven ANO 2 savice water valves not being within the IST program was not recognizing that these valves had a safety function that fell within the scope of the IST program.

However, flow verification and preventive maintenance activities are performed on

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the seven ANOo2 service water valves which has been considered to more adequately assess the valve's condition than manually stroking the valve quarterly.

(2) Corrective actions taken and results achieved:

Check valves SW 4A; BW-48i 2B_S-1 A, and 255 .18 tore smooseddyg to demonstrate their ability to close.

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An operability assessment for valves CA-61,, CA-62, BW-2, and BW-3 was performed and the valves were determined to be operable based on recent surveillance test information and peiodic maintenance.

The ANO-2 service water valves,12FP-31l2PP 46,'2SW 138,2SW-56,2SW 57c 12SW-62,' and 25W-67/'were tested successibily prior to heat-up Eom ANO 2 refueling outage 2R12.

(3) Corrective steos that will be taken to prevent recurrence:

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Test procedures will be developed by September 30,1997, to test the identified ANO l&2 valves in accordance with the IST program.

A review of engineering standards IES-17, ANO-1 IST Program Bases Document, and HES 18, ANO-2 ISTProgram Bases Document, will be performed by December 1,1997. >

An assessment of the IST program for both units will be completed by December 1,1997.

The IST program will be evaluated to determine the need for additional reviews by other departments of changes to the IST program. This action is scheduled to be completed by December 31,1997 (4) Date when full compliance will be achieved:

Full compliance was achieved on June 2,1997, when the affected valves had been successfully tested or proven operable with an operability assessment.

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[ Page 2 cf 6 f NOTICE OF DEVIATION During an NRC inspection conducted on May 12 through June 5,1997, one deviation firom a commitment was identified, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Action," NUREG 1600, the deviation is listed below:

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Arkansas Power & Light Co., letter ICAN048501, "HPI/ Makeup Nouje Component Cracking," dated April 22, 1985, submitted a final report titled,

"B&W Owners Group Safe End Task Force." The letter stated that Recommendation 3 in the report had been incorporated into the Arkansas Nuclear One Unit 1 inservice inspection plan, Recommendation 3 addressed the following nouje conditions and the associated .

nondestructive examination schedule:

Unrepaired noules were to be examined by radiography and ultraso:Jes du-ing each of the next five refueling outages, then every fifth refbeling outage thereafter, NouJes with the new sleeve design were to be similarly examined during the first, third, and flAh refueling outages, then every flAh refueling outage thereafter.

NouJes that were re rolled were to be examined by radiogrrphy during each of the next five refueling outages, then every fifth refueling outage thereaAer.

Contrary to the above,12 of the 14 committed radiographic and ultrasonic examinations scheduled for the 4 nouJes between Refueling Outage 5 and Refueling Outage 9 were not performed,-

ThisisaDeviation(50-313/9713 02),

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Response to Notice of Deviation 50 313/%13 02

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(1) Rtason for the deviation:

In response to a concern that cracking could occur in the ANO 1 high pressure injection / makeup nozzles (IIPI/MU), Arkansas Nuclear One (ANO) committed to perform augmented radiographic and ultrasonic examinations on these nozzles per Babcock and Wilcox (B&W) recommendations in 1985. The augmented examinations were included in the Inservice Inspection Program (ISI) and were scheduled for performance during five consecutive refueling outages (IRS through IR9) and then during each finh refueling outage thereafter (IR14, IR19, etc.).

The radiographic testing was to ensure no gap existed between the thermal sleeve and the safe end and to detect nozzle degradation. The ultrasonic testing was to detect cracking of the safe cred and the adjacent pipe.

The augmented examinations were performed during IRS (November 1982 - May 1983) and IR6 (October 1984 - January 1985) and only partially completed during IR7 (September 1986 - December 1986) due to program scheduling errors. The augmented radiographic examinations scheduled for 1R8 (October 1988 -

December 1988) were cancelled due to ALARA concerns without first evaluating the NRC commitment to perform the examinations.

In September 1989, ANO selfidentified the failure to perform the augmented examinations during IR7 and IR8 as previously committed to the Nuclear Regulatory Commission (NRC). An evaluation was performed to determine if the augmented examinations should be performed during a mid-cycle ounge or to delay inspections until IR9 scheduled foi October 1990. The 1, valuation concluded that since the previous augmented e ,. amination results were satisfactory and since the nozzle thermal shields were visually inspected during 1R8 and found to be intact, the augmented examinations could be delayed until IR9 (October 1990 - January 1991). The examinations performed during IR9 were deemed satisfactory.

In respc nse to the April 21,1997, HPI nozzle leak at Oconee 2, ANO reviewed radiographs and ultrasonic examinations performed during 1R9 on the ANO-1 HPI/MU nozzles and determined that the anomaly (gap between the thermal sleeve and safe end) that caused the Oconee leak was not present in the ANO-1 nozzles.

The examiners of the HPI/MU nozzle radiographs taken during past refueling outages did not document whether or not gaps existed between the thermal sleeve and the safe end area, even though the radiographs specifically depicted the thermal sleeve / safe end area.

Based on the 1997 evaluation of the past HPI/MU nozzle radiographs and ultrasonic examination test results ANO determined that additional augmented examinations were unnecessary and that the examinations could be performed on '

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l* the five refue!ing outage frequency as previously committed. The augmented

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examinations for the IIPl/MU nozzles are currently scheduled to be performed during IR14 (Spring 1998) and every fiRh refueling outage thereaRer.

Si,ce 1989 when this deviation occurred, the ANO procedure revision process and the ANO commitment management program has undergone several enhancements.

The current ANO procedure revision process requires that pending procedure changes that alter or delete exist!ng regulatory commitments be resolved per the ANO commitment mariagement program prior to implementing the change. The ANO commitment management program is currently based on the Nuclear Energy Institute's GuidelinesforManagingNRC Commitments. Commitment changes or deletions are periodically reported to the NRC based on these guidelines.

(2) Corrective actions taken and results nebleved:

The ANO.1 ISI Program was revised to include specific criteria for examination of the thermal sleeve to safa end area for gaps on the HPI/MU nozzles.

The ANO 1 ISI_ Program was reviewed to ensure that the required augmented examinations had been scheduled on the five refueling outage frequency.

(3) Actions taken to avoid further deviations:

Actions completed to date should avoid further deviations in this area.

(4) Date when corrective actions will be completed:

Corrective actions were complet:d on May 2,1997, when the evaluation of the HPI/MU nozzle radiographs taken during 1R9 determined that there were no gaps in the thermal s!: eve to safe end areas.

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w/ E 1448 $A 333 flanelhao, AR 72901 Td tot 66:~6000 Austet 25,1997 OCAN089707 U, s.NudeerRepdatory corandesion Doomment conwot oak Mail 9tesion OF117 Washington, DC 2055$

Sul(sot: Arkansas Nuclear one-Unita 1 and 2 DocketNos,50 313 and 50 368 UsenseNcs LPR 51 and NPF 4 SupplemeatalResponseTo Ingmatioa Report 50-313/97 13; 50 368/97 13 oareteman.

On July 28,1997, Arkansas Nudear One responded to the notles of violation Identl8ed durhig the inspectka of actMeles had with the Inservice Testing Program (!$T). The violation pertained to the hilure to lackade regubed ash 4B Code valves la the IST program and a -

Adlure to verify the ab8ky of other valves, which were huluded in the IST program, to Mill their elooed ensey annatia

'!he responer stated that Adi compliance was acidowed on June 2,1977, when the aftLmed valves had been suposestdly tested or proven operable with an operability assessment, However, Mowing dinoussions ydsli the region and upon Airther tuview, it has beni determined that Adl enemplianas will not be achieved until the affinsed valves are included in theist progmni, ,

To desionstress sentinued operahlthy, each velve la ededuled to be tested before the end of

ts quarterly test interval.

Unit 1 velves BW-4A, BW-48, CA41, CA42, BW 2, and DW 3 will be tested under a work plan to rnest the quarterly testing eequency. If the special test developed under the work plan is not notishetorey completed, an -===* wis be p a-... 4 to determine conthaaed operability of the valves, The resuha of the work plan will be used to dW test procedures by Septarnber 30,1997.

Test pmoedures br Unit 2 valves 2FP 31, 2FP-46, 2SW-56, 2SW 5'i, 2SW42, 28W 67, 28W-138,285-1A, and 2BS-lH have been 6.';.pd and the quarterly tests acheduled.

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. .. Aut "-If Hill fresi m 008 i HIHHell 1118 P.H/H Job-lli l' U. E. NRC Aupet 25,1997

OCAN009707 Peps 2 Fat :::- ;"-- : tw the nation arMW wEl be addem' 9 hspiamber 30.1997, when the test procedwes $nt eneb of the velves are developed, implement ed, and included la ti.e IST pasr=.

Ver/ tndy yours, dd,U.M

%c.w Wrector,IJoensing M

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,. AUG C -tr esitt FrosimioossI 51154408 T-sIIYM k Jab-Ils U. E, NRC

! August 25,1997 l* OCAN009707 Page3 l

oo: Mr. Kh W. Marschetf Regional A4ndalapsdor v.s.wuci rmaguisemyconunission RegionIV 611 Ryan PlassDrive, Suite 400 Miastoa. TX 76011.ans4 NRC seniorResidemInspmor Arkansas Nuctiv One 1448 5. R. 333 uu % At 72801 Mr. George Kakaan NRR Project Manager Ragion IV/ANO-1 & 2

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September 30,1997 f OCAN099705 N l 4M U. S, Nuclear Regulatory Commission l Document Control Desk  : 'i 7 J,

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Washington, DC 20555 Subject: Arkansas Nuclear One - Units 1 and 2 Docket Nos,50-313 and 50-368 License Nos. DPR-51 and NPF-6 Supplemental Response To Inspection Report 50 313/97-13; 50-368/97-13 Gentlemen:

On July 28, 1997, Arkansas Nuclear One (ANO) responded to the notice of violation identified during tne inspection of activities associated with the Inservice Testing (IST)

program. The violation pertained to the failure to include required ASME Code valves in the IST program and a failure to verify the ability of other check valves, which were included in the IST program, to fulfill their closed safety function.

, On August 25,1997, ANO supplemented the response and stated that check valves BW-4A, BW-4B, CA-61, CA-62, BW-2, and BW-3 would be tested pcr a temporary work plan and

' that permanent test procedures would be developed by September 30,1997.

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Valves BW-4A, BW-4B, BW-2, and BW-3 were tested satisfactorily, test procedures developed, and quarterly testing scheduled.

The system configuration for check valves CA-61 and CA-62 does not allow for testing their functional capability reliably rad repeatably. Because testing in the closed direction has been determined to be unreliable and there are no acceptable test alternatives available, check valves CA-61 and CA-62 will not be tested for closure on a quarterly basis. An operability assessment determined that both check valves are operable in the present configuration.

Check valves CA-61 and CA-62 are disassembled during alternate refueling outages and manually stroked to verify their stroke capability in both directions. Previously, credit has been taken in the IST program only for the full open stroke. Per the provisions of Generic Letter 89-04, Guidance On Developing Acceptable Inservice Testing Programs, the IST program 91- o 0 6"T l

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[f .! U. S. NRC September 30,1997

.o OCAN099705 Page 2 and IST Program Bases Document have been revised to credit the periodic disassembly and inspection as verification that these valves are capable of performing both the open and closed safety functions.

Very truly yours, .

• ONE Dwight C Mims Director, Nuclear Safety DCM/AJS cc: Mr. Ellis W. Merschoff-Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector.

Arkansas Nuc.' .wr One P.O. Box 310 London, AR 72847'

,.. Mr. George Kalman NRR Project Manager Region IV/ANO-1 & 2 U. S. Nuclear Regulatury Commission

_. NRR Mail Stop 13-H-3 One White Flint North r

11555 Rockville Pike Rockville, MD 20852

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