IR 05000313/1994020
| ML20149H111 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/09/1994 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Yelverton J ENTERGY OPERATIONS, INC. |
| References | |
| NUDOCS 9411170277 | |
| Download: ML20149H111 (4) | |
Text
.
UNITED ST ATES R REGQ
,y.
?g NUCLEAR REGULATORY COMMISSION
'
f,I
- Cf
}
nEa\\oN IV
611 RYAN PLAZA DRIVE. SUITE 400
)
Y, *4
[
AR LING TON. T E XAS 76011-8064
- y
.
p-91984
- -
l Dockets:
50-313 50-368 Licenses:
DPR-51 NPF-6 Entergy Operations. Inc.
ATTN:
J. W. Yelverton. Vice President Operations. Arkansas Nuclear One 1448 S.R. 333 Russellville. Arkansas 72801 SUBJECT:
NRC INSPECTION REPORT 50-313/94-20: 50-368/94-20 (NOTICE OF VIOLATION)
i NRC Inspection Report 50-313/94-20 50-368/94-20 was issued with an incorrect violation number on page 1 of the Notice of Violation and page 22 of the repor': and the Attachment 2. Inspection Findings Index, had incorrect finding numbers.
Please replace these pages with the enclosed corrected pages.
Sincerely, Sm u
fer-Thomas P. Gwynn, Director Division of Reactor Safety Enclosures:
1.
Corrected Notice of Violation 2.
Corrected page 22 3.
Corrected Attachment 2 cc w/ enclosure:
Entergy Operations. Inc.
ATTN:
Harry W. Keiser. Executive
!
Vice President & Chief Operating Officer P.O. Box 31995 Jackson. Mississippi 39286-1995 9411170277 941109 PDR ADOCK 05000313
. I l
PDR 4b4sd9MS
,
.
. - -
.
-
-
.
. - --
-
- -...
.
.
-
_
.
.
.
'
Entergy Operations. Inc.
-2-Entergy Operations. Inc.
.
ATTN: Jerrold G. Dewease. Vice President Operations Support-P.O. Box 31995 Jackson, Mississippi 39286
-
Wise. Carter. Child & Caraway ATTN:
Robert B. McGehee Esq.
P.O. Box 651 Jackson, Mississippi 39205 Honorable C. Doug Luningham County Judge of Pope County Pope County Courthouse Russellville. Arkansas 72801 Winston & Strawn ATTN:
Nicholas S. Reynolds. Esq.
1400 L Street. N.W.
Washington, D.C.
20005-3502 Arkansas Department of Health ATTN: Ms. Greta Dicus. Director Division of Radiation Control and Emergency Management 4815 West Markham Street Little Rock. Arkansas 72201-3867 B&W Nuclear Technologies ATTN:
Robert B. Borsum Licensing Representative 1700 Rockville Pike. Suite 525 Rockville. Maryland 20852 i
Admiral Kinnaird R. McKee USN (Ret)
214 South Morris Street Oxford. Maryland 21654
'
ABB Combustion Engineering Nuclear Power ATTN: Charles B. Brinkman Manager. Washington Nuclear Operations 12300 Twinbrook Parkway. Suite 330 Rockville. Maryland 20852
+
-,-
y.
.. - _ - -
,w-
,,
,
,,
.
.
.
.
.
Entirgy Operations. Inc.
-3-E-Mail report to D. Sullivan (DJS)
bcc to DMB (IE01)
bec distrib. by RIV:
L. J. Callan Resident Inspector Branch Chief (DRP/D)
Leah Tremper (OC/LFDCB. MS: TWFN 9E10)
MIS System DRSS-FIPB RIV File Branch Chief (DRP\\TSS)
Project Engineer (DRP/D)
RIV:C:EB W D:DRS
/% / D:DRP [ N D:DRS d TFWesterkan/lb TPGwynnbI[
AABeac [ h TPGwynn I 11/7/94 11/[/94 11/k/94 11/ 9 /94
-
-.
.
._
__
_.
_
.
. _. -
._
.
.
'
.
.
..
.
Enclosure 1 APPEND'IX A NOTICE OF VIOLATION Entergy Operations. Inc.
Dockets: 50-313 50-368 Arkansas Nuclear One Licenses:
DPR-51 NPF-6 During an NRC inspection conducted July 25-29 and August 8-12. 1994, two violations of NRC requirements were identified.
In accordance with the
'
" General Statement of Policy and Procedure for NRC Enforcement Actions."
10 CFR Part 2. Appendix C. the violations are listed below:
'
A.
Section 10 CFR 50.59. " Changes. Tests and Experiments." of the NRC Regulations states that the holder of a license authorizing operation of
a utilization facility may make changes in the facility as described in the safety analysis report without prior Ctamission approval, unless the proposed change involves a change in the Technical Specifications incorporated in the facility license or an unreviewed safety question.
'
Criterion III. " Design Control." of 10 CFR Part 50. Appendix B. states that measures shall be established to assure that the design basis, as defined in 10 CFR 50.2 and as specified in the license application, for structures, systems, and components to which this appendix applies is
<
correctly translated into specifications, drawings, procedures, and instructions.
Criterion V. "Iristructions. Procedures, and Drawings," of 10 CFR Part 50. Apaendix B. states that activities affecting cuality shall be
'
prescribed )y documented instructions. ]rocedures, or crawings of a type
appropriate to the circumstances, and slall be accomplished in accordance with these instruction, procedures or drawings.
i Arkansas Nuclear One Procedure DEAP 5010.015. " Control of Calculetions."
Revision 0 states in Step 6.1.5.A that if potential changes to
licensing basis documents result from the issuance or revision of a
'
calculation, the discipline engineer shall secure a 10 CFR 50.59 review
!
by a certified reviewer.
Contrary to the above. Calculation 91-E-0099-10. Emergency Coolir,g Pond
!
Peak Temperature and Inventory Loss Analysis Summary. Revision 0, issued on November 11. 1992, involved an apparent increase in required
'
emergency cooling pond level from that specified in the facility's licensing basis' documents and a 10 CFR 50.59 review was not pecformed.
In addition, the licensee did not initiate action to reflect the t
required pond level in the Technical Specifications, or seek NRC review of alternative compensatory actions which had not been previously reviewed by the Commission.
This 15 a Severity Level IV violation.
(Supplement I) (368/9420-02)
,
f '$ i G i 3c3Di D YPD
.
.
.
..
__
_
. _ _.
..
__
l
'
.
.
..
-2-B.
Criterion V. " Instructions. Procedures, and Drawings " of 10 CFR Part 50. Appendix 8. states, in part. that activities affecting quality shall be prescribed by documented instructions. procedures. or drawings of a type appropriate to the circumstances and shall be accomplished in
,
accordance with these instruction, procedures, or drawings.
i Arkansas Nuclear One Procedure 2311.002. " Service Water Flow Test."
Revision 8. provided a sign-off in Step 9.3 to ensure the removal of temporary instrumentation installed during the test.
Contrary to these regulrenents. Step 9.3 of Procedure 2311.002 was performed on April 10 1994, after the completion of testing on that date. but temporary ultrasonic flow instruments which had been installed
on Service Water Line 2HCC-237-2 during the 1992 refueling outage were
,
not removed.
.
This is a Severity Level IV violation.
(Supplement I) (368/9420-04)
Pursuant to the provisions of 10 CFR 2.201. Entergy Operations. Inc., is
'
hereby required to submit a written statement or explanation to the U.S.
l Nuclear Regulatory Commission. ATTN:
Document Control Desk. Washington. D C.
l 20555 with a copy to the Regional Administrator. Region IV. 611 Ryan Plaza l
Drive. Suite 400. Arlington. Texas 76011. and a copy to the NRC resident inspector at Arkansas Nuclear One, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This reply should be clearly i
marked as a " Reply to a Notice of Violation" and should include for Violation j
A:
(1) the reason for the violation, or, if contested, the basis for disputing the violation. (2) the corrective steps that have been taken and the results achieved. (3) the corrective steps that will be taken to avoid further violations. and (4) the date when full compliance will be achieved.
In view of the corrective actions taken in response to Violation B. as verified by the inspection team before completion of t1e inspection. a written response for this violation is not required.
If an adequate reply for Violation A is not received within the time specified in this Notice, an order or a Demand for Information may be issued to show cause why the license should not be l
modified, suspended. or revoked, or why such other action as may be 3 roper should not be taken.
Where good cause is shown, consideration will 3e given
'
to extending the response time.
,
Dated at Arlington. Texas this 6th day of October 1994
-
....
.
. -
-
~
.-.
,. _,
. -.,.
,
.~
_. ___
_
.
.
.
~
'
Enclosure 2
.
-reference to the effect that the proposed minimum water depth of 5 feet took into account operator action in transferring the service water system from Lake Dardanelle. Without amplifying information, a reviewer would likely have understood this reference to mean that o)erator action would preserve the minimum inventory of 70 acre-feet, not.tlat action would be needed to augment-the initial inventory with an additionally required volume of up to 9.67 acre-feet.
,
Prior to the 1992 calculation. the licensee's Technical Specifications bases did not take credit for operator action, and the licensee did not rely on the
.
actions specified in the abnormal operating procedures, to ensure the minimum required ECP inventory.
Both the calculation results and the ch;nge in operating philosophy were substantive changes'from what had prniously been made known to the NRC staff regarding ECP design requirements and operation.
t The team concluded that the minimum required ECP level determined by the 1992 calculation should have been reflected in the Technical Specifications, or that NRC review of compensatory actions to provide for ECP makeup after initiation of a design basis accident should have been requested. since the need for such actions had not been previously reviewed by the NRC.
The team noted that the licensee's failure to perform a 10 CFR 50.59 review of the 1992 calculation, and to reflect or address these results in the Technical
Specifications or their bases, was in violation of Procedure 5010.015. " Con-trol of Calculations".10 CFR 50.59: and 10 CFR 50. Appendix B. Criterion III (368/9420-04).
It also appeared that the licensee, as a result of this violation, failed to address the November 1992 calculation result in the
!
July 1993 Technical Specifications amendment request.
>
On July 25, 1994, the licencee approved Revision 1 to Calculation 91-E-0099-10.
,
That revised calculation determined that 75.13 acre-feet (64.4 inches) of ECP inventory would be required to maintain 30-day operability following a design
,
basis accident.
After discussion of the team's conclusions, as stated above.
!
the licensee committed to maintain ECP level at or above 64.5 inches, pending more permanent resolution of the issue. The licensee also initiated a review of operating records to determine whether actual ECP level had previously been below the minimum indicated by this revised calculation. The licensee noted that surveillances performed by each unit verify on at. least a-daily basis that ECP level is greater than 5 feet. 6 inches. anti that level is normally'
-
maintained at 5.8 feet.
The licensee's review determined from review of surveillance records (since December 1991) and the condition report data base that ECP level had been below 75.13 acre-feet only once since 1988.
This occurred on April 6.1992. when the level was 62.4 inches.
The licensee noted
_I that only one of the units was operating at that time, with the other unit in i
cold shutdown, and that this level would have been sufficient for the ECP to l
fulfill its safety function.
The team concluded that no operabi;-Q issue had existed during this time interval.
The licensee's treatment of the July 1994 calculation with respect to Procedure 5010.015. 10 CFR 50.59, and 10 CFR Part 50. Appendix B. was the same as for the former calculation.
However, the team concluded that this was a continuation of the violation identified above, rathe than a separate violation.
_
,, -
-
.
.
.
.
..
.
.
.
-.
'
.
..
Enclosure 3 ATTACHMENT 2
.
INSPECTION FINDINGS INDEX Inspection Followup Item 313/9420-01 was opened (Section 2.1.4).
.
Violation 368/9420 02 was ',pened (Section 2.3.3).
.
Inspection Followup Item 313/9420 03 was opened (Section 2.3.6).
.
Violation 368/9420-04 was opened (Section 3.1).
.
Inspection Followup Item 368/9010-03 was closed (Section 4.1).
.
Inspection Followup Item 313:368/9420-05 was opened (Section 4.4).
.
.
9 i
!
.
'
.
..
.
,
, Ente'gy Operations. inc.
-3-r
.
E-Mail report to D. Sullivan (DJS)
Licc to DMB (IE01)
bcc distrib. by RIV:
L. J. Callan Resident Inspector Branch Chief (DRP/D)
Leah Tremper (OC/LFDCB. MS: TWFN 9E10)
MIS System DRSS-FIPB RIV File Branch Chief (DRP\\TSS)
Project Engineer (DRP/D)
)
k
..C:EB W D:DRS
/% f D:DRP[Id D:DRS (j TFWesterkan/lb TPGwynnYf AABaac [ h TPGwynn I 11/7/94 11/[/94 11/h/94 11/ 9 /94
.
-
.