IR 05000313/1997003

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-313/97-03 & 50-368/97-03

ML20198G167
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/08/1997
From:	Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Hutchinson C ENTERGY OPERATIONS, INC.
References
50-313-97-03, 50-313-97-3, 50-368-97-03, 50-368-97-3, NUDOCS 9708130382
Download: ML20198G167 (4)

Text

__

, .

uniit2 st Atis Su:ug'%

y. NUCLEAR REGULATORY COMMISSION

$ < REoloN lv 611 RYAN PLAZA ORivt, SulTE 400 k,*****

4 AR LINGioN, T E XAS 76011-8064 AUG - 81997 C. Randy Hutchinson, Vice President Operations Arkansas Nuclear One Entergy Operations, Inc.

1448 S.R. 333 Russellville, Arkansas 72801 0967 l

SUBJECT: NRC INSPECTION REPORT 50 313/97-03; 50 368/97 03

Dear Mr. Hutchinson:

Thank you for your letter of July 31,1997, regarding the referenced Notice of Violation dated July 1,1997, for failure to adhere to procedures for refueling operations for new and spent fuel storage. We will review the Implementation of your corrective actions during a future Inspection to determine that full compliance has been achieved and will be malntained.

Sincerely, ( h Thomas P. Gwynn, Director Division of Reactor Projects Docket Nos.: 50 313 50 368 License Nos.: DPR 51 NPF 6

.

cc:

Executive Vice President

& Chief Operating Officer Entergy Operations, Inc.

((

P.O. Box 31995 Jackson, Mississippi 39286 1995

'

9708130382 970000 $ff!hffl PDR ADOCK 05000313 g PDR

- -- .. .

.

. . . . . . . . . . . .

. . . _ .. .

. .

_.

y

i

. * ,

! l i

i

,

-I

'

Entergy Opera'tlons, Inc. - 2'  !

u i l J  !

'

!

i Vice President

l Operations Support  !

,

Entergy Operations, Inc.

! P.O. Box 31995 i

{ Jackson, Mississippi 39280 i Manager, Washington Nuclear Operations - . - _

. -

ABB Combustion Engineering Nuclear ,

Power

- 12300 Twinbrook Parkway, Suite 330_ .;

I Rockville, Maryland 20852 +

i

) County Judge of Pope County ,

1 - Pope County Courthouse ,

! Russellville, Arkansas 72801 L ,

i

'

Winston & Strawn '

1400 L Street, N.W. '

] Washington, D.C. 20005 3502 J

'

David D. Snellings, Jr., Director *

!. Division of Radiation Control and

' Emergency Management

! . Arkansas Department of Health

4815 West Markham Street, Mc!I Slot 30 Little Rock, Arkansas- 72205 3367 i Manager

}- Rockville Nuclear Licensing i- Framatome Technologies

, 1700 Rockville Pike, Suite 525 i Rockville, Maryland 20852

-

' -

s b

_

'

i Ii e

.

-a r- v + w vv -vw--* -t *'*#er'e'""

-

+ -

'",-wiew-w-+,r-**v + -r*~-e--ww 1-pr re---we ew+-w we wsw e w w rwv-~m-- -k e-w-,,rw-w-w---r-=-wwrw- *v, -v,wr -e - - -- -,+-wrewe,w'y'e-

Entergy Operations, Inc. 3 g ,g bec to DCD (IE01)

bec distrib by RIV:

.

'

Regional Administrator Resident inspector DRP Director MIS System Branch Chief (DRP/C) RIV Filo Project Engineer (DRP/C) DRS-PSB

! Branch Chief (DRP\TSS)

DOCUMENT NAME: R:\_ANO\AN703AK.KMK To receive copy of document, irdcate in boo "C" = Copy with prx}osures "E" = Copy with enclosures "N" = No copy RIV:PE:DRP/C % C:DBPJC D:DRP U$ I CSMarschall:df EECollin's TPGwynn h*

8/'y /97 - 8/ //97 8/@ (.97 OFFIC:AL HECORD COPY l

i

. .

. .

Entergy Operations, Inc. - -34 g ,g lisiiNdsVsiisf/

bec distrib. by RIV:

Regional Administrator Resident inspector DRP Director MIS System

.

Branch Chief (DRP/C) RI V File l Project Engineer (DRP/C) DRS PSB Branch Chief (DRP\TSS)

- DOCUMENT NAME: R:\_ANO\AN703AK,KMK

- To receive copy of document. Ind6cate in boa: "C" = Copy wthe nc30sures *E" = Copy wth enclosures *N" = No copy -

RIV:PE:DRP/C 10h C:DFJC D:DRP (f5 CSMarschall;df - EECo'lliH~s TPGwynn P 8/7/97- 8/ //97 8/F G7 OFFICIAL HECORD COPY

,

.

g:; . . ,

.

e' Jy eni.,s, e,.,:ii n.. io,.

} / id48$R 333 Raanese AR 723;)

7d's01 BEBG<4

-

- . .

10CFR2.201

[Tlj, it it it li k

. - -

-

.,

July 31,1997 g 4g7:.

I 2CAN079706 ' - J REGION N U. S. Nuclear Regulatory Commission Document Control Desk, OPl-17 Washington, DC 2055$

I Subject: Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF 6

'

L Response To Inspection Report

50 313/97-03;50-368/97-03

'

Gentlemen:

Pursuant to the provisions of 10CFR2.201, attached is the response to the notice of violation identified during the inspection activities associated with the placement of a fuel assembly in a location in the spent fbel pool which was prohibited by technical specifications.

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

Very truly yours, Ne~kt' ~17%

Dwight C. Mims Director, Nuclear Safety DCM/ajs Attachments hy p

- o

U. S. NRC

• *

July 31,1997

-

.- 2CAN079706 PAGE 2

,

cc: Mr. Ellis W. Mert.choff j Regional Adminletrator

U. S. Nuclear Regulatory Commission

.

Region IV j 611 Ryan Plaza Drive, Suite 400 Arlington, TX 760118064 i

i NRC Senior Resident Inspector

'

Arkansas Nuclear One P.O. Box 310

! . London, AR 72847 Mr. Gecrge Kalman

-

NRR Project Manager Region IV/ANO.1 & 2

U. S. Nuclear Regulatory Commission i

-

NRR Mail Stop 13113

One %%te Flint Nonh 11555 Rockville Pike Rockville, MD 20852 l

_

_

'-

Attachment 13

' '

2CAN079706

.- Page 1 cf 5 NOTICE OF VIOLATION During an NRC inspection conducted on April 27 through June 7,1997, two violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below: ,

A. The information regarding the reason for the violation and the corrective actions to correct the violation and prevent recu Tence are addressed in Licensee Event Report 50-368/97 002 00, No response is required to this violation.

B. Technical Specification 6.8.1 states, in part, that written procedures be established,

--

implemented, and maintained covering the activities for both refbeling operations and for new and spent fbel storage.

i

'

1. Procedure 1022.012, Revision 18, " Storage, Control & Accountability of Special Nuclear Material," Step 6.3.1, requires, prior to movement of fuel assemblies to the spent fuel pool, that two qualified individuals perform independent reviews to determine the classification ofibel assemblies using _

- Attachment 5 of the procedure and' documenting the results on Form 1022.012U, " Unit 2 Nuclear Fuel Location Record." Procedure 1022.012, Attachment 5, Step 2.0, used to calculate fbel assembly average burnup, requires that an adjustment factor of 0.93 be applied to the measured fbel assembly burnup to account for measurement uncertainties.

Contrary to the above, a reactor engineer failed to apply the a4ustment fhetor to the measured fuel assembly burnup when calculating the average burnup for the ibel assemblies to be of!!oaded from the reactor vessel to the spent fbel pool and did not document the results on Form 1022.012U.

As a result, 42 of 177 fbel assemblies were classi6ed incorrectly, resulting in one fuel assembly being placed in a spent fuel pool location prohibited by Technical Specifications.

2. Procedure 1022.012, Revision 18, " Storage, Control & Accountability of Special Nuclear Material," Step 6.3.1, requires, prior to movement of fuel assemblies to the spent fbel pool, that two qualified individuals perfonn independent reviews to determine the classification of fuel assemblies.

Contrary to - the above,. an independent review to determine the classification of fuel assemblies was not performed prior to the movement of fuel from the reactor vessel to the spent fuel pool on May 18,1997.

)

• '

Attachment t)

• '

2CAN079706

.

'

Page 2 cf 5 3. Procedure 1022.012, Revision 18, " Storage, Control & Accountability of Special Nuclear Material," Step 6.3.4, requires, that Form 1022.012B,

" Nuclear Fuel Transfer Report," be independently reviewed by a qualified individual to verify special nuclear material storage in locations in compliance with Steps 6.3.1,6.3.2, and 6.3.3.

Contrary to the above, the independent reviewer failed tri verify compliance with Steps 6.3.1 and 6.3.2 in that Fonn 1022.012Us were not reviewed.

This is a Severity Level IV violation (Supplement 1)(Violation 50-368/9703-04).

Response to Notice Of Violation 313/9702 01: 368/9702 01 (1) Reason for the violation:

Storage locations in the ANO 2 spent fuel pool (SFP) are restricted based on initial fuel cruichment and fuel assembly average burnup. Procedure 1022,012, Storage, i Control & Accountability of Special Nuclear Material, provides instmctions to l calculate and document the restriction classification for fuel assemblics to be stored in the SFP. A bumup adjustment factor of 0.93 is used to account for measurement uncertainties in the measured fuel assembly burnup.

Procedure 1022.012 was revised on March 1,1997, due to a change to the ANO 2 Technical Specifications allowing storage of fuel with enrichments as high as 5.0 weight percent. This revision increased the number of restriction categories from two to four. The first opportunity to use the new procedure to classify fuel assemblies was when the new fuel arrived in preparation for the 2R12 refueling outage. A spreadsheet was developed to perform the multiple calculations for classifying the new fuel assemblies. No burnup adjustment factor was applied to the calculation since the new assemblies had no burnup.

The same spreadsheet was used a second time when end of cycle bumup projections were calculated for an advance determination of the fuel shuffle sequence. Before the fuel shuffle sequence can be completed the fuel assemblies in the reactor core must be classified to determine an appropriate SFP location for each assembly. The spreadsheet was used but an independent calculation was not required. Thus, the missing burnup adjustment factor was not detected.

Once the reactor shutdown was completed, the actual end of cycle burnup was calculated. Again, the spreadsheet developed previously was used to determine the classification of the fuel assemblies. Since the results compared favorably with the end of cycle projections, one individual was assigned to update the fbel location records while another was completing the fuel shuffle sequence report. Procedure 1022.012 requires that, prior to movement of fuel to the SFP, two qualified individuals perform

. . . . . . . .

. .

.

.. .. .. .

.

.

o Attachment t)

• *

2CAN079706

.- Page 3 cf 5 independent reviews to determine the restriction classl5 cation of the fbel assemblies ami document the results on form 1022.012U, Unit 2 Nuclear Fuel Locat/on Record.

The sequence report was completed but the independent check for classincation did not occur prior to the report being delivered to the control room for use. - The indepenJe.it reviewer for the fbel shuffle sequence report signed form 1022.012B the Nuclear Fuel hansfer Report without having consulted form 1022.012U Unit 2 NuclearFuelLocation Record.

Approximately one hour before the start of the core omload, the Reactor Engineering Superintendent discovered the fbel location record forms with the independent review unalsned. Knowing the fbel shuffle wquence report was completed, he assumed the absence of a second signature was just an administrative oversight and that the independent reviews had been completed. However, to ensure that they were in fhet completed and properly documented, a day shlR individual was assigned to perform 3 the second calculations. The superintendent believed these calculations could be completed expeditiously in the sequence of the omload, thereby completing the

- - - -

required documentation before each specific move.

Due to support of other core omload activities, the second calculations were delayed l  : and not started until aRer fbel movement had commenced. A night shlR individual discovered his calculations were not correlating with the first results and identified that the initial calculation did not include the burnup adjustment factor, When the error was verified, all fbel movement was stopped. A total of seven fbel assemblies had been moved into the SFP, but only one assembly was found to be inappropriately located. An allowed storage location for this assembly was identified and it was relocated to the newlocation.

Subsequent calculations determined that 42 of the 177 fbel assemblics had been assigned the wrong classification due to the enor in the original calculation. Had the error not been detected,14 of these misclassified anemblies would have been placed in inappropriate locations. The other- 28 fbel assemblies, although originally misclassified. were destined for allowable storage locations in the original fuel shuffle

.

sequence.

Two root causes were identified for this event. First, was the failure to follow the procedural guidance. Attachment 5 to procedure 1022.012 provides instruction for conservatively calculating the fbel assembly bumup to account for uncertainties associated with power measurements and power distribution. The individual who prepared the, form 1022.012U, failed to utilize this procedural guidance to determine the adjusted fbel' assembly burnup. Second, was the failure to perform a proper second person verification when the independent reviewer signed the Nuclear Fuel hansfer Report, form 1022.012B, without having consulted form 1022.012U Unit 2 Nuclear Fuellocation Record.

_ _ _ _ _ _ _ _ _ __ __. . _ _ _ _ _ _ _ _ - _ - _ - .

_ - . _ .

-

'

Attachment 13

2CAN079706

,

'

Page 4 of 5 (2) Correctiw stens that have been taken and the results achieved:

The misplaced fuel assembly was relocated to its proper SFP region.

A complete recalculation for all fuel assemblies to be offloaded from the core was performed to verify that the assemblies were correctly classified. A second calculation was performed independently to verify the results of the first calculation. Additionally, two other individuals performed independent _ calculations on randomly selected assemblies to verify agreement with the Arst calculation, i

Reviews were conducted of the ANO 1 SFP and the ANO 2 SFP to ensure the fbelis l

'

stored in the correct regions. No deficiencies were identified.

Briefings were conducted with Reactor and System Engineers to discuss the '

management expectations concerning the performance ofindependent re'4ews.

.

.

!

Prior to recommencing fbel handling operations both the ANO 2 System Engineering i Manager and the ANO.2 Plant Manager were briefed on the event and the conective i actions taken.

An evaluation was made of the ANO 2 SFP for a complete offload of the cycle 12 i core in the originally designated locations. This evaluation concluded that K.efroctive would have been maintained below the licensing basis analysis value even with the i assumption of 0 ppm boron in the SFP.

'

(3) C,orrective stens that will be taken to avoid further violations:  !

a improvements in Job Specific Training to specifically address fuel moves will be evaluated and identified changes will be implemented for Reactor Engineers by  ;

June 30,1998.

Expectctions for procedure. usage and independent reviews for Reactor, System, Design, and Maintenance Engineers will be documented and communicated to the appropriate personnel by December 19,1997, i

'

Iassons learned firom this event will be evaluated and included in appropriate departmental continuing trtiining by December 19,1997. l Procedure 1022.012 will be revised by December 19, 1997, to incorporate place.

keeping and appropriate cautions to address this condition.

.... - . - .- - - - . - - - - - , - - --

'*

'

Attachment to

2CAN079706 -

. Page 5 cf 5 (4) Date when Aall comollance will be achieved:

Full compliance was achieved on May 19,1997, when the inappropriately positioned Ibel assembly was relocated to an allowed storage location and the fbel classification calculations were conectly reperformed and independently verified.

!

!

_ _

-

%