0CAN122201, Reply to a Notice of Violation; EA-22-099

Reply to a Notice of Violation; EA-22-099

ML22342B267
Person / Time
Site:	Arkansas Nuclear
Issue date:	12/08/2022
From:	Keele R Entergy Operations
To:	NRC Region 4, Document Control Desk, Office of Nuclear Reactor Regulation
References
0CAN122201, EA-22-099
Download: ML22342B267 (1)

Text

) entergy Riley D. Keele, Jr.

Manager, Regulatory Assurance Arkansas Nuclear One Tel 479-858-7826 10 CFR 2.201 0CAN122201 December 8, 2022 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Reply to a Notice of Violation; EA-22-099 Arkansas Nuclear One, Units 1 and 2 NRC Docket Nos. 50-313 and 50-368 Renewed Facility Operating License Nos. DPR-51 and NPF-6

Reference:

NRC letter to Entergy, "Notice of Violation, NRC Inspection Report 05000313/2022011 and 05000368/2022011," (0CNA 112203) (ML22301A153),

dated November 9, 2022

Dear Sir or Madam:

By the reference above, the NRC issued Entergy Operations, Inc. (Entergy) a green Notice of Violation (NOV) for Arkansas Nuclear One (ANO) for failure to manage the effects of aging on the buried Unit 1 and Unit 2 Service Water supply piping as required by regulatory requirements. Specifically, when managing the effects of aging, the licensee has not performed thickness measurements of its buried in-scope Emergency Cooling Pond supply piping and provided reasonable assurance that the Service Water system remains capable of performing its design function. The NOV requires a written response within 30 days addressing the following: reason for the violation, corrective steps that have been taken and results achieved, corrective steps that will be taken, and date when full compliance will be achieved. Enclosure 1 provides Entergy's response to the NOV.

The new commitments contained in this submittal are provided in Enclosure 2.

Should you have any questions, please contact Mr. Riley Keele at 479-858-7826.

Respectfully, lc~~4-RDK/ble Entergy Operations, Inc. 1448 SR 333, Russellville, AR 72802

0CAN122201 Page 2 of 2

Enclosures:

1. Response to Notice of Violation

2. List of Regulatory Commitments cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - Arkansas Nuclear One NRC Project Manager - Arkansas Nuclear One R4Enforcement@nrc.gov

Enclosure 1 0CAN122201 Response to Notice of Violation

0CAN122201 Page 1 of 3 Response to Notice of Violation Description of Violation:

Failure to Perform Required Thickness Measurements as Required by Design to Manage the Effects of Aging Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.5] - Work 71003 Systems VIO 05000313,05000368/2022011-01 Management Open EA-22-099 The team identified a green finding and associated Notice of Violation because the licensee failed to manage the effects of aging on the buried unit 1 and unit 2 service water supply piping as required by regulatory requirements. Specifically, the licensee failed to measure pipe wall thickness to assess the condition of the supply piping that provides cooling during a design basis accident.

Entergy documented the violation in its Corrective Action Program and a causal analysis was performed to identify and correct the underlying causes for this failure.

Reason for the violation:

Inspection plans scheduled in previous refueling outages were inappropriately deferred due to an inadequate understanding and application of the applicable regulatory requirements. Causal factors contributing to this include:

Previous changes to program owner alignment and responsibilities in the Microbiologically Influenced Corrosion (MIC) and Buried Piping programs.

This led to gaps in the advocacy and ownership of the applicable regulatory-related inspection requirements for the Unit 1 and Unit 2 Emergency Cooling Pond (ECP) supply piping.

Inadequate management oversight led to inspection deferrals. The Arkansas Nuclear One (ANO) Plant Health Committee did not provide effective oversight of the project established to replace the Emergency Cooling Pond supply piping. This resulted in deferral of the required inspections to support the project without an adequate regulatory basis to support the deferral.

Improper justification of aging management barriers. Comparison data related to non-chemically treated piping was utilized as inappropriate justification for deferring the inspections for the Emergency Cooling Pond supply piping. Additionally, programmatic inspection points were removed from the ANO MIC program in 2021 for unknown reasons or justification.

0CAN122201 Page 2 of 3 Corrective steps that have been taken and results achieved:

During the ANO Unit 1 (ANO-1) fall 2022 refueling outage (1R30), Entergy performed non-destructive examination (NDE) of the Service Water Emergency Cooling Pond supply piping utilizing automated ultrasonic testing (AUT). The results of the AUT showed that no indications were observed below the critical thickness acceptance criteria. In addition, the remaining service life calculation shows that NDE inspections should be performed within ten years to establish a new remaining service life or determine a need for piping replacement. This inspection would need to occur prior to 1R36 which is currently scheduled in 2031.

Plant Health Committee weaknesses were addressed early in 2022 to improve oversight of the deferral of projects by ensuring the basis for the deferral was acceptable and that any bridging strategy needs were appropriately implemented.

Corrective steps that will be taken:

During the upcoming ANO Unit 2 (ANO-2) spring 2023 refueling outage (2R29), Entergy plans to perform NDE of the ANO-2 Service Water Emergency Cooling Pond buried supply piping. The inspection results will be used to establish a remaining service life, determine if replacement activities are required, and establish re-inspection intervals to determine a new remaining service life.

The ANO MIC Program (SEP-MIC-ANO-001) is being revised to provide clarification and confirmation that MIC-susceptible buried piping will be included in future inspection scope. This clarity will ensure inspection requirements are understood and that unexpected turnovers of program ownership will be appropriately mitigated by explicit program guidance. Additionally, information contained in ANO Engineering Report CALC-A-EP-2005-001 ANO MIC Program is being reviewed for inclusion into SEP-MIC-ANO-001 in order to have only one programmatic controlling document for the MIC Program. Conflicting and unclear guidance between these two documents challenged a thorough understanding of the required program inspections.

MIC program qualification requirements will be completed for the current MIC Program Owner and a backup engineer. Previous unexpected program owner turnover and transfer of responsibilities led to inadequate advocacy and ownership of the program requirements due to filling the program owner vacancies with personnel with little experience or knowledge of the MIC program.

Date when full compliance will be achieved:

Full compliance will be achieved by completion of the 2R29 refueling outage, scheduled for spring of 2023, once the following actions have been completed:

MIC Program (SEP-MIC-ANO-001) is revised to provide clarification and confirmation that MIC-susceptible buried piping will be included in the inspection scope.

0CAN122201 Page 3 of 3 MIC Program owner and backup have completed their qualifications.

NDE inspection of the ANO-2 ECP supply piping is performed during the spring 2023 refueling outage. This will ensure thickness data has been captured for both ANO-1 and ANO-2 ECP supply piping, providing the basis for continued service life of this piping and/or required repair or replacement activities.

Enclosure 2 0CAN122201 List of Regulatory Commitments

0CAN122201 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy Operations, Inc. (Entergy) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE SCHEDULED (Check One) COMPLETION COMMITMENT ONE-TIME CONTINUING DATE ACTION COMPLIANCE (If Required)

Entergy will revise the Microbiological Influenced Corrosion Program (SEP-MIC-ANO-001) to provide X March 17, 2023 clarification and confirmation that MIC-susceptible buried piping will be included in future inspection scope.

MIC program qualification requirements will be completed for the X April 14, 2023 current MIC Program owner and a backup engineer.

Entergy will perform a non-destructive examination inspection of the Arkansas Nuclear One, Unit 2 X End of 2R29 Emergency Cooling Pond supply piping during the upcoming 2R29 refueling outage.