ML16232A618

Revised Non Cited Violation; NRC Inspection Report 05000313/2015002 and 05000368/2015002

ML16232A618
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/19/2016
From:	Kennedy K Region 4 Administrator
To:	Warren C Entergy Operations
O'Keefe C
References
EA-15-194 IR 2015002
Download: ML16232A618 (9)

See also: IR 05000313/2015002

Text

August 19, 2016

EA-15-194

Clay Warren, Acting Site Vice President

Arkansas Nuclear One

Entergy Operations, Inc.

1448 SR 333

Russellville, AR 72802-0967

SUBJECT: ARKANSAS NUCLEAR ONE - REVISED NON-CITED VIOLATION; NRC

INSPECTION REPORT 05000313/2015002 AND 05000368/2015002

Dear Mr. Warren:

On August 5, 2015, the U.S. Nuclear Regulatory Commission (NRC) issued NRC Inspection

Report 05000313/2015002 and 05000368/2015002 that included a non-cited violation of Title 10

of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XI, Test Control,

documenting the failure to adequately test the emergency diesel generator fuel oil transfer piping

(Agencywide Documents Access and Management System (ADAMS) ML15218A371).

In a written response dated September 3, 2015 (ML15246A591), you denied the non-cited

violation (NCV 05000313/2015002-04, 05000368/2015002-04) associated with the failure to

adequately test the emergency diesel generator fuel oil transfer piping and indicated that you

were in compliance with regulatory requirements. On October 9, 2015, the NRC acknowledged

receipt of your letter (ML15282A338) and informed you that we would review the basis for your

denial.

The NRC conducted a detailed review of your response and the applicable regulatory

requirements, in accordance with Part I, Section 2.2.8 of the NRC Enforcement Manual.

Individuals who were not involved with the original inspection effort performed this review.

After consideration of the bases for your denial of the non-cited violation, the NRC has concluded

that a violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, related to the failure

to establish an adequate testing program for the emergency diesel generator fuel oil transfer

piping for Arkansas Nuclear One, Units 1 and 2, is appropriate. However, the NRC also

concluded that the original non-cited violation references to 10 CFR 50.55a(g)(1) and

10 CFR 50.55a(g)(4) should be removed. Therefore, a revision to the subject NRC inspection

report will be issued to remove the 10 CFR 50.55a(g)(1) and 10 CFR 50.55a(g)(4) references in

the non-cited violation. The details of the NRCs evaluation are contained in the enclosure.

In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a

copy of this letter and its enclosure will be made available electronically for public inspection in

the NRC Public Document Room and from ADAMS, accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html.

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD.

ARLINGTON, TX 76011-4511

C. Warren

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If you have any questions about this matter, please contact Heather Gepford, Chief, Plant Support

Branch 2, Division of Reactor Safety, at 817-200-1156.

Sincerely,

/RA/

Kriss M. Kennedy

Regional Administrator

Dockets: 50-313; 50-368

Licenses: DPR-51; NPF-6

Enclosure:

NRC Evaluation of Licensee

Response to Non-Cited Violation

cc w/encl.: Electronic Distribution

ML16232A618

SUNSI Review

By: HJG1

ADAMS

Yes No

Publicly Available

Non-Publicly Available

Non-Sensitive

Sensitive

Keyword:

NRC-002

OFFICE

AEA

C:PSB2

SES:ACES

RC

TL:ACES

NAME

LBerger

HGepford

JKramer

KFuller

MHay

SIGNATURE

/RA/

/RA/

/RA/

/RA/

/RA/

DATE

06/16/16

06/16/16

06/22/16

06/23/16

06/24/16

OFFICE

C:DRPB

D:DRS

OE

RA

NAME

NOKeefe

AVegel

GFigueroa

KKennedy

SIGNATURE

JDixon for

/RA/

/RA/

/RA/

DATE

07/14/16

06/30/16

07/11/16

08/19/16

Enclosure

NRC EVALUATION OF LICENSEE RESPONSE TO NON-CITED VIOLATION

Restatement of the Violation

Title 10 CFR Part 50, Appendix B, Criterion XI, Test Control, requires, in part, that a test

program shall be established to assure that all testing required to demonstrate that structures,

systems, and components will perform satisfactorily in service is identified and performed in

accordance with written test procedures, which incorporate the requirements and acceptance

limits contained in applicable design documents.

For facilities with a construction permit issued prior to January 1, 1971, 10 CFR 50.55a(g)(1)

states, in part, that components (including supports) must meet the requirements of

paragraphs (g)(4) and (g)(5) of this section to the extent practical. Components that are part of

the reactor coolant pressure boundary and their supports must meet the requirements

applicable to components that are classified as ASME Code Class 1. Other safety-related

pressure vessels, piping, pumps and valves, and their supports must meet the requirements

applicable to components that are classified as ASME Code Class 2 or 3.

Title 10 CFR 50.55a(g)(4) states, in part, that components that are classified as ASME Code

Class 1, 2, and 3 must meet the requirements set forth in Section XI of the ASME Code. ASME

Code,Section XI, Table IWD-2500-1, Examination Category D-B, Item D2.10, requires a system

leakage test and a VT-2 visual examination for pressure retaining components. For buried

components where a VT-2 visual examination cannot be performed, Table IWA-5244(b)(1)

requires that the system pressure test for buried components that are isolable by means of

valves shall consist of a test that determines the rate of pressure loss. Alternatively, the test

may determine the change in flow between the ends of the buried components.

Contrary to the above, from initial commercial operations to April 29, 2015, the licensee failed to

establish a test program to assure that all testing required to demonstrate that the fuel oil

transfer piping will perform satisfactorily in service is identified and performed in accordance

with written procedures, which incorporate the requirements and acceptance limits contained in

applicable design documents.

Specifically, the licensee did not establish inservice inspection examinations and testing

required by 10 CFR 50.55a(g)(1) and (g)(4) and, as specified by ASME Code,Section XI,

Tables IWD-2500-1 and IWA- 5244(b)(1), to detect degradation of the fuel oil piping above

ground and buried between the fuel oil storage tanks and the emergency diesel generator day

tanks. Since the violation is of very low safety significance and is documented in the licensees

corrective action program as Condition Report CR-ANO-2-2015-01092, it is being treated as a

non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy.

(NCV 05000313/2015002-04, 05000368/2015002-04; Failure to Perform Testing of Diesel Fuel

Oil Transfer Piping)

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Summary of the Licensees Response

In response to NCV 05000313/2015002-04, 05000368/2015002-04, Failure to Perform Testing

of Diesel Fuel Oil Transfer Piping, the licensee provided a letter dated September 3, 2015,

which contested the non-cited violation. The letter provided the basis for disputing the non-cited

violation.

The licensee summarized its understanding of the specific points of the violation to be:

Arkansas Nuclear One Units 1 and 2 had not established and maintained an adequate

testing program for the fuel oil transfer piping to meet the requirements of 10 CFR Part 50,

Appendix B, Criterion XI, Test Control.

The failure to meet 10 CFR Part 50, Appendix B, Criterion XI, was caused by not including

the subject piping in the ASME,Section XI, boundaries and by not performing the

inspections of ASME,Section XI, as required by the regulations cited by the NRC in

Section 1R08.b.2 of the subject inspection report.

The licensee denied that a violation of NRC requirements had occurred, in that, extending the

Units 1 and 2 ASME,Section XI, boundaries to include the diesel fuel oil piping is beyond the

plants licensing basis and exceeds the requirements of the regulations cited within the

non-cited violation. In addition, the licensee believed that the non-cited violation inappropriately

applied the same regulation to both units without distinguishing the regulatory uniqueness of the

units based on construction permit dates.

The licensee further stated that the safety evaluation issued by the NRC for approval of the

extended operating period for both units determined that adequate actions were taken by the

licensee for aging management of the diesel fuel oil system. Further, the aging management

programs, combined with the surveillance testing required by the plants technical specifications,

provide adequate assurance that the fuel oil piping remains acceptable.

NRC Independent Review

The NRC performed an independent review of the documentation associated with this finding.

To evaluate the validity of the non-cited violation and address the licensees response to the

non-cited violation, the review examined two key areas:

Reference to 10 CFR 50.55a(g)(1) in the non-cited violation

Assessment of compliance with 10 CFR Part 50, Appendix B, Criterion XI

Reference to 10 CFR 50.55a(g)(1) in the Non-Cited Violation

When reviewing documentation during the inspection, the inspector noted the design

documents for both units fuel oil systems were dated 1970. Based on this, and the licensees

lack of documentation demonstrating the Unit 2 diesel fuel oil system was designed under the

Unit 2 construction permit (December 6, 1972), the inspector concluded that the systems were

both designed under the Unit 1 construction permit (December 6, 1968).

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However, with respect to the non-cited violation, the NRC has determined the date of the fuel oil

system design documents is not relevant. The requirements of 10 CFR 50.55a(g)(1) and (g)(2)

reference the date of the facilitys construction permit, not the date the system in question was

designed. Further, the NRC reviewed the Unit 2 Safety Evaluation Report, which stated, in part,

The date of the applicants [sic] construction permit (December 6, 1972) places this plant under

10 CFR 50.55a(g)(2)... As a result, the NRC agrees with the licensees contention that

10 CFR 50.55a(g)(1) does not apply to Unit 2. The NCV 05000368/2015002-04, as written, was

incorrect.

The NRC determined that all plants, regardless of construction permit date, are required to meet

the inservice inspection requirements of 10 CFR 50.55a(g)(4) and (g)(5). The NRC noted that

paragraph 10 CFR 50.55a(g)(1) states that pre-1971 construction permit plants must meet

10 CFR 50.55a(g)(4) and (g)(5) to the extent practical. By use of the words to the extent

practical, this requirement acknowledges that when the plants were designed there was no

ASME,Section XI, and it may not be possible to meet all the inspection requirements of

Section XI. The NRC also noted that 10 CFR 50.55a(g)(4) explicitly excludes the design and

access provisions and preservice examination requirements specified in ASME,Section XI,

thus, limiting the scope of Section XI requirements that must be met. Neither

10 CFR 50.55a(g)(1) or (g)(2) were intended to change the design basis of the plant. However,

they are intended to ensure the scope of components tested for earlier licensed plants is similar

to those licensed later.

The NRC reviewed guidance documents for insights on the classification of the diesel fuel oil

transfer system. Regulatory Guide 1.26, Quality Group Classifications and Standards for

Water-, Steam-, and Radioactive-Waste-Containing Components, Revision 1, was issued in

September 1974. The NRC noted that Regulatory Guide 1.26 and its subsequent revisions

state that the guide should be applied to water-, steam-, and radioactive-waste-containing

components. The guidance further states, Other systems not covered by this guide, such as

instrument and service air, diesel engines and their generators and auxiliary support systems,

diesel fuel, emergency and normal ventilation, fuel handling, and radioactive waste

management systems, should be designed, fabricated, erected, and tested to quality standards

commensurate with the safety function to be performed.

In contrast, Standard Review Plan, NUREG-75/087, dated November 24, 1975, Section 3.2.2,

System Quality Group Classification, III. Review Procedures, states, in part, There are also

systems of light-water-cooled reactors important to safety that are not identified in Regulatory

Guide 1.26 and which the NRC considers should be classified Quality Group C. Examples of

these systems are: diesel fuel oil system; diesel generator cooling This demonstrates one of

the inconsistencies identified in NRC guidance documents with respect to classification of the

diesel fuel oil system.

The NRC reviewed the units Safety Analysis Reports to determine whether the diesel fuel

transfer piping was classified as equivalent to Class 3. The NRC determined that the Safety

Analysis Reports were inconsistent, which contributed to the difficulty of evaluating the validity

of the non-cited violation as written. For example, the Unit 2 Safety Analysis Report,

Table 3.2-3, specifies the emergency diesel fuel transfer pump is Code Group C and classified

as ASME III, Class 3.

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The table includes a note that the Code Group applies to the process piping and components,

not to the instrument sensing lines. This seems to be consistent with Safety Guide 26, Quality

Group Classifications and Standards, published March 23, 1972, which states, The system

boundary includes those portions of the system required to accomplish the specified safety

function and connected piping up to and including the first valve (including a safety or relief

valve) that is either normally closed or capable of automatic closure when the safety function is

required. Taken together, the NRC initially concluded that the Unit 2 diesel fuel transfer pump

piping was Code Group C and was classified by the licensee as ASME III, Class 3, in spite of it

being designed to ASME B31.1. (Note: The Safety Analysis Report for Unit 1 does not contain

this information on the Code Group and classification for the diesel fuel transfer pump.)

Relative to the non-cited violation in question, Unit 2 is subject to the requirements of

10 CFR 50.55a(g)(2) and, as previously stated, not required to comply with

10 CFR 50.55a(g)(1). The NRC determined that all plants, regardless of construction permit

date, are required to meet the inservice inspection requirements of 50.55a(g)(4) and (g)(5).

However, the NRC found that both units licensing basis was unclear as to whether the diesel

fuel oil transfer system is considered to be Code Class 3. In addition, industry standards and

the NRCs guidance have changed over the years for the diesel fuel oil transfer system. For

these reasons, the NRC concluded that referencing 10 CFR 50.55a(g)(1) and (g)(4) in the

non-cited violation confused the issue and detracted from the underlying performance

deficiency.

Assessment of Compliance with 10 CFR Part 50, Appendix B, Criterion XI

The violation was cited against 10 CFR Part 50, Appendix B, Criterion XI, Test Control,

because the licensee did not have an adequate testing program for the fuel oil transfer piping.

Notwithstanding ASME Code,Section XI, requirements, the failure to perform testing in

accordance with written procedures that incorporate the requirements and acceptance limits

contained in applicable design documents would be a nonconformance with 10 CFR Part 50,

Appendix B, Criterion XI. The NRC noted that the fuel oil transfer piping for both units was

safety-related Seismic Class 1 piping, designed and built to ASME Code B31.1.0 requirements.

In the response letter, the licensee provided additional information on the testing of the fuel oil

transfer piping that was not provided to the inspector during the inspection. This information

included surveillance testing performed for the emergency diesel generator as defined by Unit 1

Technical Specification Surveillance Requirement 3.8.1.6. Technical Specification Surveillance

Requirement 3.8.1.6 states, Once every 31 days, verify the fuel oil transfer system operates to

transfer fuel oil from storage tanks to the day tank. This is further explained in the technical

specification surveillance requirement bases, which states, This Surveillance demonstrates that

each required fuel oil transfer pump operates and transfers fuel oil from its associated storage

tank to its associated day tank. This is required to support continuous operation of standby

power sources. This Surveillance provides assurance that the fuel oil transfer pump is

OPERABLE, the fuel oil piping system is intact, and the fuel delivery piping is not obstructed.

The licensee also referenced the equivalent Unit 2 surveillance testing performed for the

emergency diesel generator as defined by Technical Specification Surveillance

Requirement 4.8.1.1.2.a.3 and 4.8.1.1.2.a.13. Specifically, Technical Specification Surveillance

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Requirement 4.8.1.1.2 states, Each diesel generator shall be demonstrated OPERABLE: a. At

least once per 31 days on a STAGGERED TEST BASIS by: 3. Verifying the fuel transfer pump

can be started and transfers fuel from the storage system to the day tank. Additionally,

Technical Specification Surveillance Requirement 4.8.1.1.2.c. states, Each diesel generator

shall be demonstrated OPERABLE: c. At least once per 18 months by: 13. Verifying that the fuel

transfer pump transfers fuel from each fuel storage tank to the day tank of each diesel via the

installed cross connection lines.

The licensee further stated that the emergency diesel generator operating procedures for both

units contained specific instructions that require identification and disposition of leaks detected

during or after surveillance tests. However, the NRC concluded that the described surveillances

for Units 1 and 2 do not incorporate the requirements and acceptance limits contained in

applicable design documents for the fuel oil transfer piping. The NRC also noted that portions

of the piping are buried and leaks would not be evident.

The licensees response letter stated that programs and procedures had been established for

the purpose of maintaining the diesel fuel oil transfer piping system commensurate with its

importance to safety. These procedures include monthly testing to verify the quality of the

diesel fuel oil is maintained according to the industry guidelines, including verifying that moisture

is not present. The NRC agrees that ensuring a lack of moisture in the stored fuel minimizes

the risk of internal corrosion; however, testing the fuel oil quality does not demonstrate that the

piping can meet its safety-related function.

The licensee also stated that the buried piping program verifies that the external coating of the

buried portions of the piping is maintained to prevent degradation of the piping outer diameter,

and functional testing of the relevant valves and pumps of the emergency diesel generating fuel

oil system are included in the inservice testing program. The licensee stated that the safety

evaluation issued by the NRC for approval of the extended operating period for both units

determined that adequate actions were taken by the licensee for aging management of the

diesel fuel oil system.

However, the NRC reviewed the licenses renewal application and noted that the buried piping

program only performs opportunistic inspections of the protective coating when plant

maintenance or modifications uncover portions of the piping. Further, the purpose of these

inspections is to ensure that a loss of material due to external surface corrosion is adequately

managed. Therefore, the NRC concluded that the buried piping program inspections do not

demonstrate the piping will perform satisfactorily in service. Specifically, these inspections do

not demonstrate the structural integrity of the piping or that the piping continues to meet the

design criteria for Seismic Class 1 components or the design criteria of ASME B31.1.

In summary, the licensee offered that the aging management programs combined with the

surveillance testing required by the plants technical specifications provided adequate

assurance that the fuel oil piping remains acceptable. The NRC determined that the licensees

conclusion was incorrect and that a violation of 10 CFR Part 50, Appendix B, Criterion XI, Test

Control, did occur.

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NRC Conclusion

The violation was written to be applicable to both Units 1 and 2. The inclusion of reference to

10 CFR 50.55a(g)(1) in the violation was inappropriate as the construction permit dates for the

units are different. The NRC concluded that the appropriate requirement for Unit 2 was

10 CFR 50.55a(g)(2), rather than 10 CFR 50.55(g)(1), as cited. However, 10 CFR 50.55a(g)(4)

is applicable to both units.

During review of this issue, the NRC found that the licensing basis for both units was unclear on

whether the diesel fuel oil transfer system should be considered equivalent to ASME Code

Class 3. In addition, industry standards and the NRCs guidance have changed over the years

for the diesel fuel oil system. For these reasons, the NRC concluded that referencing the

testing requirements of 10 CFR 50.55a(g)(4) in the non-cited violation confused the issue and

detracted from the underlying performance deficiency.

The licensee stated that the aging management programs combined with the surveillance

testing required by the plants technical specifications provided adequate assurance that the fuel

oil piping remains acceptable. The NRC determined that the licensees conclusion was

incorrect and that a violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, did

occur. Therefore, the non-cited violation is being upheld but revised to remove the references

to 10 CFR 50.55a(g)(1) and 10 CFR 50.55a(g)(4).