IR 05000313/2011006
| ML110890925 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 03/29/2011 |
| From: | Hay M NRC/RGN-IV/DRP |
| To: | Schwarz C Entergy Operations |
| References | |
| IR-11-006 | |
| Download: ML110890925 (23) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION IV
612 EAST LAMAR BLVD, SUITE 400 ARLINGTON, TEXAS 76011-4125 March 29, 2011 Christopher Schwarz, Vice President, Operations Arkansas Nuclear One Entergy Operations, Inc.
1448 S.R. 333 Russellville, AR 72802 Subject: ARKANSAS NUCLEAR ONE - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000313/2011006 AND 05000368/2011006
Dear Mr. Schwarz:
On February 18, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed a team inspection at your Arkansas Nuclear One facility. The enclosed inspection report documents the inspection findings, which were discussed on February' 18, 2011, with Mr. M. Chisum, General Manager, Plant Operations, and other members of your staff.
The inspection examined activities conducted under your license as they relate to identification and resolution of problems, safety and compliance with the Commission's rules and regulations and with the conditions of your operating license. The team reviewed selected procedures and records, observed activities, and interviewed personnel. The team also interviewed a representative sample of personnel regarding the condition of your safety conscious work environment.
Based on the samples selected for review and the interviews conducted, the inspection team concluded that Arkansas Nuclear One, Units 1 and 2, was generally effective in identifying, evaluating and resolving problems. The team determined that your plant personnel consistently identified problems and entered them into the corrective action program at a low threshold. The team noted that plant personnel appropriately screened issues for operability and reportability, and prioritized issues commensurate with the safety significance of the problems. The team also determined that the facility has a strong safety conscious work environment. Although the team concluded that the implementation of your corrective action program at Arkansas Nuclear One, Units 1 and 2, was generally effective, this report documents one NRC-identified finding of very low safety significance (Green). The finding was determined to involve a violation of NRC requirements. However, because of the very low safety significance of the violation and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest this non-cited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, D.C. 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV; 612 East Lamar Blvd., Suite 400, Ariington, Texas 76011-4125; the Director, Office of Enforcement, U.S. Nuclear Regulatory
Inc.
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Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspectors at the Arkansas Nuclear One, Units 1 and 2, facility.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web-site at
\\'wNrI.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Docket: 50-313 and 50-368 License: DPR-51 and NPF-6
Enclosure:
Sincerely, 1WJ(.~
Michael Hay, Chief, Technical Support Branch Division of Reactor Projects NRC Inspection Report 05000313/2011006; 05000368/2011006 w/Attachment: Supplemental Information
REGION IV==
05000313 and 05000368 DPR 51 and NPF 6 05000313/2011006 and 05000368/2011006 Entergy Operations, Inc.
Arkansas Nuclear One, Units 1 and 2 Russellville, Arkansas January 31 through February 18, 2011 M. Davis, Senior Resident Inspector i. Anchondo, Reactor Engineer W. Schaup, Resident Inspector G. Tutak, Project Engineer Michael Hay, Chief, Technical Support Branch Division of Reactor Safety
iR05000313/201106; 05000368/2011006; 01/31 - 2/18/2011; the Identification and Resolution of Problems" The team inspection was performed by one senior resident inspector, one resident inspector, and two regional inspectors. One finding of very low safety significance (Green) was identified during this inspection. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609, "Significance Determination Process". Findings for which the significance determination process does not apply, may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG 1649, "Reactor Oversight Process," Revision 4, dated December 2006.
Identification and Resolution of Problems The team concluded that site was generally effective in identifying, evaluating, and resolving problems. Plant personnel consistently identified problems and entered them into the corrective action program at a low threshold. In general, the licensee appropriately screened issues for operability and reportability, and prioritized issues commensurate with the safety significance of the problems. The licensee effectively used industry operating experience when performing root cause and apparent cause evaluations and appropriately evaluated industry operating experience for relevance to the facility and had entered applicable items in the corrective action program. The licensee performed effective quality assurance audits and self assessments.
Additionally, the team concluded from interviews that a healthy safety conscious work environment exists were personnel felt free to raise safety concerns.
Although the team concluded that the implementation of the licensee's corrective action program at Arkansas Nuclear One, Units 1 and 2, was generally effective and that the documentation and tracking of corrective actions were adequate, the team identified some minor exceptions in the following areas: (1) Identification of Issues, (2) Prioritization and Evaluation of Issues, (3) Effective of Corrective Actions, (4) Use of Operating Experience, and (5) Self Assessments and Audits.
Cornerstone: Mitigating Systems
Green. The team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," because the licensee did not promptly identify and correct a condition adverse to quality that affected static uninterruptible power supply inverters used to power vital and safety related loads. Specifically, the licensee did not identify and correct an issue with undersized constant voltage transformers installed in safety-related 120-volt alternate current inverters. As a result, when a constant voltage transformer in one of the inverters became saturated from a voltage spike or electrical malfunction, it would impact an entire train of inverters. The licensee entered this issue into their corrective action program for resolution as CR-ANO-C-2011-0440. The immediate corrective actions following the additional failures included installation of direct current fuses. The planned corrective actions included installation of a
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Enclosure
to in the "1 current inverter to prevent faults or transients from adversely affecting the other inverters connected to the same bus.
This finding is greater than minor because it is associated with the design and equipment performance attributes of the Mitigating System cornerstone and affects the cornerstone objective to ensure the availability and reliability of safety-related inverters that respond to initiating events to prevent undesirable consequences in that these inverters supply power to vital and safety related loads. The inspectors evaluated the significance of this finding using Phase 1 of the IMe 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations" given the importance of the system and the fact that this condition affected an entire train of safety-related inverters due to a voltage spike or electrical malfunction. The inspectors determined that the finding was of very low safety significance (Green) because it is not a qualification deficiency, did not represent a loss of a safety function of a system or a single train greater than its Technical Specification completion time, and did not screen as potentially risk significant due to external events. The inspectors did not assign a crosscutting aspect because the finding is not reflective of current performance (Section 40A2.S).
Other Findings Licensee - Identified Violations None.
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4.
OTHER (OA)
40A2 Problem Identification and Resolution (Biennial 71152)
The team based the following conclusions on the sample of corrective action documents that were initiated in the assessment period, which ranged from February 20, 2009, through the end of the on-site portion of the inspection on February 18, 2011.
. 1 Assessment of the Corrective Action Program Effectiveness a.
Inspection Scope The team reviewed several hundred condition reports, including associated root cause, apparent cause, and direct cause evaluations, from approximately twelve thousand condition reports that had been issued between February 20, 2009, and February 18, 2011, to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. The team reviewed a sample of system health reports, operability determinations, self-assessments, trending reports and metrics, and various other documents related to the corrective action program. The team evaluated the licensee's efforts in establishing the scope of problems by reviewing selected databases, work requests and orders, self-assessments results, audits, system reports, and results from surveillance tests and preventive maintenance tasks. The team attended the licensee's Condition Review Group screening committee meetings and Corrective Action Review Board meetings to assess the reporting threshold, prioritization efforts, and significance determination process, as well as observe the interfaces with different organizations and processes when applicable. The team's review included verifying that the iicensee considered the full extent of cause and extent of condition for problems, as well as how the licensee assessed generic implications and previous occurrences. The team assessed the timeliness and effectiveness of completed or planned corrective actions, and looked for additional examples of similar problems. The team conducted interviews with plant personnel to identify other processes that may exist where problems may be identified and addressed outside the corrective action program.
The team also reviewed corrective action documents that addressed past NRC-identified violations to ensure that the corrective actions addressed the issues as described in the inspection reports. The inspectors reviewed a sample of corrective actions closed to other corrective action documents to ensure that corrective actions were still appropriate and timely.
Furthermore, the team reviewed condition reports selected across the seven cornerstones of safety in the NRC's Reactor Oversight Process. The team seiected a risk-informed sample of condition reports that had been processed through the corrective action program and that had been issued since the last team inspection. The team considered risk insights from the NRC's and licensee's risk assessments to focus
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Enclosure
the sample selection on risk-significant systems and components. The samples focused on, but were not limited to these above mention systems. The team also expanded the corrective action review to include five years of evaluations involving the following systems: (1) 480 volt motor control center loads, (2) the Unit 2, 120 volt alternate current system, and (3) the service water system to determine whether problems were being effectively addressed. Additionally, the team conducted walkdowns of these systems to assess if problems were being identified and entered into the corrective action program.
b.
Assessments 1. Assessment - Effectiveness of Problem Identification Based on the samples selected and plant tours, the team determined that the licensee personnel identified problems and entered them into the corrective action program in accordance with the licensee's corrective action program guidance and NRC requirements. The team determined that the licensee was identifying problems at a low threshold because over 13,000 condition reports were written during the two year period of review. However, the team did identify some examples of conditions adverse to quality that were not placed in the licensee's corrective action program. Those examples are as follows:
e The team identified an issue of concern with the preventive maintenance deferral process in that one procedure referred to a time requirement in another procedure, which had been deleted. The team concluded that with no time requirement to complete evaluations before deferring the performance of a preventive maintenance task beyond its late date could potentially extend a preventive maintenance task without proper justification. The licensee entered this issue into their corrective action program as CR-HQN-2011-0126 for resolution. The team did not identify any preventive maintenance tasks that were beyond their specific date without a proper justification.
- The team identified a latent procedure issue related to the licensee's operator work around and main control room deficiencies process in that the corporate procedure and site-specific procedure did not contain the same guidance on identifying, tracking, and correcting plant deficiencies that impacted Operations. The team noted during a control room \\AJa!kdovvn that the control room deficiencies \\AJere being tracked in several areas and were not readily available for the control room staff to obtain. The team also noted that there was a lack of operator knowledge as to which guidance to follow due to the conflicting information. The team concluded that with this conflicting guidance this could delay the resolution of deficiencies and make it difficult to assess the cumulative effects for operator work around and main control room deficiencies. The licensee entered this issue into their corrective action program for resolution as CR-ANO-C-2011-0142.
"
The team reviewed two category jD' condition reports ANO-1-201 0-281 0 and ANO-2-2009-3417, respectively. These particular condition reports were closed to work orders that did not have the correct work order priority associated with them as required by operating procedures OP-1107-004 and OP-21 07-004, respectively. The
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Enclosure
procedures state, in part, that if voltages on a direct current bus fall below a certain value then perform the following: (1) Contact the system engineer; (2) Initiate a maintenance call-out, and (3) Initiate emergency maintenance and a priority 1 work request and/or work order to repair the degraded condition. In both cases, operators initiated a priority 2 work request. The team concluded that operators did not follow procedures as written. The licensee entered this issue into their corrective action program as CR-ANO-1-2011-0268 for resolution. The team determined that this issue is minor because it involved an administrative requirement that had no safety impact.
2. Assessment - Effectiveness of Prioritization and Evaluation of Issues The team determined that, in general, the licensee appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem.
The team screened a number of condition reports that involved operability and reportability reviews to assess the quality, timeliness, and prioritization of these issues.
The team noted that the immediate and prompt operability assessments reviewed were completed in a timely manner. The team also noted that for the most part the evaluations were thorough such that the resolutions addressed causes and extent of conditions, as necessary. However, the team identified an exception with a root cause evaluation. The team reviewed condition report, ANO-1-201 0-2056, and its associated non-cited violation 2010003-06 that documented a failure of the licensee personnel to follow procedure, which led to a reactor trip. The team noted that the root cause evaluation and the corrective actions to prevent reoccurrence did not fully address the non-cited violation. The licensee determined that the cause of the reactor trip was a faiiure to follow procedure and the corrective action to prevent reoccurrence was to change the procedure. The team determined that a change in the procedure did
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evaluation addressed the behavior issue of not following procedures. Additionally, the root cause evaluation did not include all the organizational and programmatic weakness associated with the contributing causes identified in the evaluation. This is contrary to the procedure requirements contained in Section 5.2.3 of EN-Ll-118, Root Cause Analysis Process. The inspectors noted to the licensee that the cause and corrective action did not conform to their procedural guidance. The licensee also identified areas of concern with this evaluation and decided to revise the root cause evaluation. The licensee entered this issue into their corrective action program as CR=I\\NO=>C~201 0-02920 for resolution.
3. Assessment - Effectiveness of Corrective Action Program Overall, the team concluded that the licensee developed appropriate corrective actions to address problems. The team determined that corrective actions for identified deficiencies were generally timely and adequately implemented. In most cases, the licensee appropriately self-identified ineffective or improper closeout of corrective actions. However, the team noted instances were corrective actions were not fully effective and implemented in a timely manner. Some examples included:
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Enclosure
4>>
2, i volt vital power system has experience multiple inverter failures since installation in 1999. The team identified a non-cited violation that is discussed in Section 40A2.5
'"
The team reviewed condition report ANO-C-2010-1676 written to address a non-cited violation 2010402-01 for security waivers. The team noted that the condition report was improperly closed to another condition report that did not take into account the actions necessary to resolve the non-cited violation. This is contrary to the procedure requirements contained in Section 5.10 of EN-Ll-1 02, Corrective Action Process. The team determined that this issue is minor because even though it was improperly closed the actions to resolve the non-cited violation were addressed in another condition report. The licensee entered this issue into their corrective action program as CR-ANO-1-2011-00428 for resolution.
- The team reviewed a self assessment for the Boric Acid Corrosion Control Program, LO-ALO-2008-90. The team identified that the corrective actions associated with the self assessment contained due dates extended without proper approvals. This is contrary to the procedure requirements contained in Section 5.5 of EN-Ll~1 04, Self-Assessment and Benchmark Process. Additionally, the team noted that corrective action number 8 was not completed. The team determined that this issue is minor because it involved administrative requirements that had no safety impact, although the corrective actions were not implemented in a timely fashion. The licensee entered these issues into their corrective action program as CR-ANO-C-2011-00376 and CR-ANO-C-2011-00376 for resolution, respectively.
- The team reviewed ANO-1-2010-0404, which documented a fire impairment that impacted the diesel fire pump's ability to start from the control room. The licensee implemented a fire \\AJatch but did not assign any corrective actions to resolve the issue. The team concluded that the condition report was closed without actually resolving the issue. The licensee entered this issue into their corrective action program as CR-ANO-1-2011-00426 for resolution. The team determined that this issue is minor because compensatory measures were in place.
- The team reviewed ANO-C-201 0-0654, a roll-up condition report, which documented minor security equipment deficiencies. The team noted that this condition report documented deficiencies from 2008 that \\tvere never corrected from the original condition report. The team determined that this issue is minor because it did not result in a reasonable doubt on the operability of the equipment and the licensee has compensatory measures in place.
. 2 Assessment of the Use of Operating Experience a.
Inspection Scope The team examined the licensee's program for reviewing industry operating experience, including reviewing the governing procedure and self assessments. The team reviewed a number of operating experience notifications that had been issued during the assessment period to assess whether the licensee had appropriately evaluated the-7 Enclosure
notification for relevance to the facility.
team also examined whether the licensee had entered those items into their corrective action program and assigned actions to address the issues. The team reviewed a sample of root cause evaluations and corrective action documents to verify if the licensee had appropriately included industry operating experience.
b.
Assessment Overall, the team determined that the licensee adequately evaluated industry operating experience for relevance to the facility, based on a number of industry operating experience reviewed. The inspectors concluded that the licensee entered applicable items in the corrective action program in accordance with station procedures. The team concluded that the licensee evaluated industry operating experience when performing root and apparent cause evaluations. Both internal and external operating experience was being incorporated into lessons learned for training and pre-job briefs. However, the team noted an exception as a part of the review. The team reviewed CR-ANO-2009-1421 and the associated apparent cause evaluation that documented a condition in which a past operability evaluation of a High Energy Line Barrier (HELB) Door was not thoroughly evaluated because the door was unlatched. The team noted a potential weakness in the licensee's risk assessment guidelines because it did not, in all cases, account for increase risk when a HELB door became inoperable or out of service for maintenance related activities. The team determined that if the licensee had screened applicable operating experience such as the NRC Regulatory Issue Summary (RIS)
2001-09, Control of Hazards Barriers, then the licensee should have risk assessed or determined the impact of an unlatched HELB door. As a result, the team requested a copy of the screening evaluation for NRC RIS 2001-09 since this operating experience was applicable to both units. The team noted that the licensee could not retrieve a copy f'lf tho 0\\1<:111 I <:It if'l n I\\lIf'1rof'l\\lor tho lif'onc>oQ h",rI '" rliff;f" tit +;""0 rotr;o,,;n,.., "thor inf"r,.,..,,,ti,,....
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1IIIVllilCALIVlI related to other NRC related operating experience such as regulatory issue summaries and information notices, prior to 2005. The team concluded that the licensee may have a weakness in the area of NRC related operating experience.
. 3 Assessment of Self-Assessments and Audits a.
Inspection Scope The team reviewed a sample population of the licensee's self-assessments, surveillances, and audits to assess whether the licensee was regularly identifying performance trends and effectively addressing them. The team reviewed audit reports to assess the effectiveness of assessments in specific areas. The team evaluated the use of self and third party assessments, the role of the quality assurance department, and the role of the performance improvement group related to the licensee's performance. The specific self-assessment documents reviewed are included in the attachment to this report.
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Enclosure
b.
Assessment The team concluded that audits and self-assessments were critical and, in most cases, appropriate actions were taken to address identified issues. The team determined that corrective actions associated with identified issues were implemented commensurate with their safety significance. However, the team noted in one case that the licensee was not as critical. As a part of the team condition report review, the team noted that the licensee generated an adverse trend condition report ANO-C-2009-00074 due to a large number of preventive maintenance deferral problems. The team reviewed the engineering/maintenance self-assessment (QA-04-2009-ANO-1) and noted that the licensee did not identify this adverse trend with the preventive maintenance program, when part of the scope of the audit was to review this particular aspect of the program.
The team determined that this was a missed opportunity to evaluate and resolve an issue with the preventive maintenance program through the licensee's self assessment process.
. 4 Assessment of Safety-Conscious Work Environment a.
Inspection Scoge The inspection team conducted individual interviews with a number of individuals across different departments. The individuals performed various functions throughout the organization and at different levels such as contractors, staff, and supervisors. The team conducted these interviews to assess whether conditions existed that would challenge the establishment of a safety conscious work environment at Arkansas Nuclear One, Units 1 and 2.
b. Assessment The team determined that the plant staff were aware of the importance of having a strong safety conscious work environment and expressed a willingness to raise safety issues. No one interviewed had experienced retaliation for safety issues raised, or knew of anyone who had failed to raise issues. Based on a limited number of interviews, the team concluded that there was no evidence of an unacceptable safety conscious work environment. In most cases, the plant staff knew who the Employee Concerns Program coordinator was but did not necessary know where the office was located or knew that the Employee Concerns Program was an avenue to raise safety concerns. The team observed this when conducting interviews with groups of one to three years of experience and was only limited to certain Departments. However, those particular Department employees' felt comfortable in bringing any concerns to their supervisors.
. 5 Specific Issues Identified During This Inspection Failure to Resolve Adverse Conditions in a Timely Manner related to 120 Volt Vital Inverters 9 -
Enclosure
Introduction. The team identified a Green finding associated with a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," because the licensee did not promptly identified and correct a condition adverse to quality that affected static uninterruptible power supply inverters used to power vital and safety related loads.
Specifically, the licensee did not identify and correct an issue with undersized constant voltage transformers installed in safety-related 120-volt vital inverters. As a result, when a constant voltage transformer (CVT) in one of the inverters became saturated from a voltage spike or electrical malfunction, it would impact an entire train of inverters.
Description. On September 4, 2008, an entire train of 120-volt alternate current (VAC)
vital inverters failed due to blown fuses from a fault in a transfer switch. At the time of this occurrence, Unit 2 Operators were attempting to place the vital inverter 2Y-11 on its alternate source in preparation for parallel operation with the swing inverter 2Y -1113.
During the transfer operation, the 2Y-11 experienced a fault on the static transfer control board, which caused the inverter's output voltage to increase from 120 VAC to 125 VAC.
This positive step change caused the inverter's constant voltage transformer (CVT)
windings to saturate. The CVT is not designed to operate in a saturated region. The voltage transient through the CVT caused the direct current (DC) input fuses in 2Y -11, 2Y-1113, and 2Y-13 to blow. The licensee initiated a higher tier apparent cause evaluation ANO-2-2008-2076 and determined that the apparent cause was blown fuses caused by a saturated CVT.
The team reviewed the apparent cause evaluation, associated condition reports, work orders, and other related documents as a part of the five year review. The team noted that the licensee had previous failures dating back to the initial installation of the 120 volt vital inverters. The first failure occurred during inverter startup activities, on January 27, 1999, when a fault in 2Y-22 caused the fuse to blow in another inverter 2Y-24. On October 4, 2000, 2Y-1113 malfunctioned when operators attempted to place it in service.
This failure caused the fuses to blow in 2Y -11 and 2Y -13. For the above failures, the licensee corrected the conditions that led to the initial faults, but did not evaluate a single failure having an adverse affect on the other inverters in the train. On November 8, 2006, 2Y-22 failed and the fuses in 2Y-2224 and 2Y-24 blew. The licensee determined that a voltage transient through the CVT caused the other inverters' DC input fuses to blow due to the CVT operating in a saturated region. For each of these conditions identified above, a single failure impacted other inverters in the train. The corrective actions performed for each case was to replace the input fuses.
The team determined that the licensee missed opportunities to identify and correct a condition adverse to quality related to an undersized CVT that affected an entire train of vital inverters. The licensee entered the issue into their corrective action program for resolution as CR-ANO-C-2011-0440. The licensee evaluated the condition adverse to quality and determined that a modification to install a blocking diode in the 125 VDC input of each vital inverter would prevent future faults from affecting multiple inverters connected to the same DC bus.
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Enclosure
Analysis. The peliormance deficiency is that the licensee did not identify and correct an issue with undersized constant voltage transformers installed in safety-related 120-volt vital inverters in a timely manner.
licensee missed opportunities to identify and correct this issue during previous evaluations of failures. As a result, when a constant voltage transformer (CVT) in one of the inverters became saturated from a voltage spike or electrical malfunction, it would impact an entire train of inverters. This finding is greater than minor because it is associated with the design and equipment performance attributes of the Mitigating System cornerstone and affects the cornerstone objective to ensure the availability and reliability of safety-related inverters that respond to initiating events to prevent undesirable consequences in that these inverters supply power to vital and safety related loads. The inspectors evaluated the significance of this finding using Phase 1 of the IMC 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations" given the importance of the system and the fact that this condition affected an entire train of safety-related inverters due to a voltage spike or electrical malfunction. The inspectors determined that the finding was of very low safety significance (Green) because it is not a qualification deficiency, did not represent a loss of a safety function of a system or a single train greater than its Technical Specification completion time, and did not screen as potentially risk significant due to external events.
The inspectors did not assign a crosscutting aspect because the finding is not reflective of current performance.
Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action,"
requires, in part, measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. Contrary to the above, from 1999 through September 4, 2008, the licensee missed opportunities to identify and correct a problem of single inverter faults affecting the entire train of inverters in a timely manner. Because the violation is of very !ow safety significance and has been entered into the licensee's corrective action program as Condition Report CR-ANO-C-2011-0440, this violation is being treated as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy: NCV 05000368/2011006-01, "Failure to Resolve Adverse Conditions in a Timely Manner Related to the 120 Volt Vital inverters."
40A6 Meetings Exit Meeting Summary On February 18, 2011, the resident inspectors presented the inspection results to Mr. M.
Chisum, General Manager, Plant Operations, and other members of the licensee's staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
ATTACHMENTS: SUPPLEMENTAL iNFORMATION 11 -
Enclosure
POINTS Entergy Personnel C. Schwarz, Site Vice President, Operations M. Chisum, General Manager, Plant Operations D. James, Director, Nuclear Safety Assurance CONTACT J. Eichenberger, Manager, Corrective Actions and Assessments S. Pyle, Acting Manager, Licensing B. Lorin, Manager, Security B. Short, Licensing Specialist D. Fowler, Manager, Quality Assurance J. McCoy, Director, Engineering L. McCarty, Corrective Actions and Assessments Specialist R. Phillips, Manager, Planning, Scheduling, and Outages S. Cotton, Manager, Training NRC Personnel M. Hay, Chief, Technical Support Branch M. Davis, Team Leader, Senior Resident Inspector LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened and Closed 05000368/2011006-01 NCV Failure to Resolve Adverse Conditions in 120 Volt Vital Inverters in a Timely Manner (40A2.5)
A - 1 -
Attachment
Section Problem Identification and ProcedureslDocuments 1015.033 1104.024 1104.025 1104.027 1107.004 1304.043 2104.005 2106.009 2107.001 2307.043 COPO-13 COPO-20 COPD-24 EN-AD-102
EN-DC-153 EN-DC-203 EN-DC-204 EN-DC-205 EN-DC-206 EN-DC-324 EN-DC-335 EN-DC-340 EN-FAP-OP-006 EN-FAP-WM-008 EN-FAP-WM-011 Title Switch yard Controls Instrument Air System Service Air System Battery and Switchgear Emergency Cooling System Battery and 125 V DC Distribution Unit 1 Reactor Protection System Channel C Calibration Containment Spray Turbine Generator Operations Electrical System Operations Unit 2 2D-11, 2D-12 and 2D-13 Battery Yearly Inspection Operations Maintenance Interface Standards/Expectations ANO Operations Concerns Program Risk Assessment Guidelines Procedure Adherence and Temporary Modifications of Use Preventive Maintenance Component Classification Maintenance Rule Program Maintenance Rule Scope and Basis Maintenance Rule Monitoring Maintenance Rule (a)( 1) Process Preventive Maintenance Program PM Basis Template Microbiology Influenced Corrosion Monitoring Program Operator Aggregate Impact Index Performance Indicator Outage Preparation and Recovery Work Planning Standard A-2-Revision
38
37
43
60
4
9
5
5
2
1
2 o
o o
o Attachment
EN-U-104 EN-U-118 EN-U-118-06 EN-U-119 EN-U-121 EN-MA-101 EN-NS-102 EN-NS-117 EN-NS-200 EN-NS-215 EN-OM-123 EN-OP-102 EN-OP-102 EN-OP-104 EN-OP-104 EN-OP-104 EN-OP-iii EN-OP-115 EN-QV-108 EN-QV-109 EN-QV-126 EN-QV-128 EN-TQ-212 OP-1015.001 OP-1015.048 OP-1203.008 OP-1203.025 OP-2305.054 Condition Reports ANO-1-2010-0711 Review Process Self-Assessment and Benchmark Process Root Cause Analysis Process Common Cause Analysis (CCA)
Apparent Cause Evaluation (ACE) Process Entergy Trending Process Conduct of Maintenance Fitness for Duty Program Fitness for Duty Process Security Reporting Requirements Conduct of Security Force Exercises and Drills Fatigue Management Program Protective and Caution Tagging Protective and Caution Tagging Operability Determination Process Operability Determination Process Operability Determination Process Operational Decision-making Issue Process Conduct of Operations QA Surveillance Process Audit Process Oversight Follow-Up Procedure Assessments of Nuclear Oversight Conduct of Training and Qualification Scheduling Conduct of Operations Shutdown Operations Plan Natural Emergencies (Unit 2)
Natural Emergencies (Unit 1)
Offsite Power Transfer Test ANO-1-2008-0637 ANO-1-2010-0627 A - 3-
16
13
11
9
6
10
13
5
4
5
19
4
5
3
32
ANO-1-2010-0892 Attachment
1-201 0-01 ANO-2-2009-0817 ANO-2-2010-3294 ANO-1-2009-0476 ANO-1-2009-0819 ANO-1-2009-0959 ANO-2-2009-3234 ANO-2-2010-0473 ANO-1-2008-0649 ANO-2-2009-0964 ANO-I-20i0-3113 ANO-1-2010-3255 ANO-i-20i0-3260 ANO-1-20i0-0348 ANO-i-20i0-3078 ANO-C-2010-2166 ANO-C-2010-3197 ANO-C-2010-1866 ANO-1-2010-2815 ANO-I-2010-2819 ANO-1-2010-2822 ANO-1-20 10-0850 ANO-C-2010-2787 ANO-2-2010-2476 ANO-i-2010-3563 ANO-C-2010-2896 ANO-C-2009-2662 ANO-C-2009-2664 ANO-C-2009-2669 ANO-2 -2009-0308 ANO-C-2009-2652 ANO-1-20i0-1795 ANO-C-2009-0934 ANO-2-2009-2031 ANO-C-2009-2637 ANO-C-2009-2642 ANO-1-2009-2340 ANO-2-2010-0032 ANO-C-2009-2597 ANO-C-2009-0580 ANO-C-2009-0140 ANO-C-2010-0497 ANO-2-2009-2576 ANO-2-2009-2600 ANO-2-2009-2658 ANO-C-2010-2913 ANO-2-2010-2488 ANO-2-2010-2543 ANO-2-2010-2594 ANO-2-2010-2685 ANO-C-2009-2420 ANO-C-20i 0-1 058 ANO-2-2010-0417 ANO-C-2010-1687 ANO-C-2009-2405 ANO-C-2010-1470 ANO-2-2009-0275 ANO-C-2010-2502 ANO-C-2009-2378 ANO-C-2010-1275 ANO-2-2009-1801 ANO-C-2010-1888 ANO-1-2010-2333 ANO-I-20i0-2680 ANO-1-20i0-2979 ANO-1-20i0-3069 ANO-2 -2009-2324 ANO-2-2009-2330 ANO-2-2009-2244 ANO-2-2009-2471 ANO-C-2009-2326 ANO-C-2010-1288 ANO-2-2009-3646 ANO-C-2010-1862 ANO-1-2009-2297 ANO-i-20i0-1316 ANO-2-2009-0788 ANO-2-2009-1200 ANO-C-2009-2241 ANO-2-2009-3515 ANO-C-2009-2349 ANO-2-2009-3785 ANO-i-20i0-2231 ANO-i-2010-2821 ANO-i-20i0-2822 ANO-1-2010-3037 ANO-C-2010-2119 ANO-C-2009-1209 ANO-1-2009-1322 ANO-2-2009-2i49 ANO-C-2009-2118 ANO-C-2009-1315 ANO-C-2009-0002 ANO-C-2010-0977 ANO-C-2009-2107 ANO-C-201 0-1 071 ANO-2-2010-0911 ANO-C-2010-1560 ANO-i-2009-2061 ANO-i-20i0-0908 ANO-C-2008-2033 ANO-1-2009-0876 ANO-i-20i0-2056 ANO-C-2009-0406 ANO-C-2009-0059 ANO-C-2009-0811 ANO-2-2009-2019 ANO-2-2009-2021 ANO-2-2009-2074 ANO-2-2009-2242 ANO-1-2009-1996 ANO-C-2010-0118 ANO-C-2010-0163 ANO-C-2010-0515 ANO-2-2008-1965 ANO-2-2010-2186 ANO-2-2010-1925 ANO-2-2010-1796 ANO-2-2010-1790 ANO-2-2010-1787 ANO-2-2010-1718 ANO-C-2010-0329 ANO-C-2009-1627 A "If> '1 '1(V'Ir. ')')70 A....,1""\\ '"' "1\\(\\ "t"7nn 1\\ "1.1""'\\ r. I"\\f'\\A r.. r;,,...,,-y r\\1'I. V-,c.-,c.UU;;;J-,.hJ I U
/"\\1 'I. V-L-LUU;:1-L I UU MI\\lV-I..J-LU I U-UU":> {
ANO-2-2010-01622 ANO-2-2010-2404 ANO-2-2010-0338 ANO-i-20i0-0316 A-4-Attachment
619 0-0671 0-0903 ANO-C-201 488 0-1-2009-0066-2009-0058 ANO-2-2007-1512 ANO-2-2006-2496 ANO-C-2008-1140 ANO-C-2009-0074 ANO-1-2009-1421 ANO-C-2011-0428 ANO-C-2011-0426 ANO-C-2011-0412 ANO-C-2009-1393 ANO-C-2009-1394 ANO-C-2010-0726 ANO-C-201 0-1 037 ANO-C-2009-1386 ANO-C-2009-1908 ANO-1-2009-2167 ANO-C-2010-1126 ANO-C-2009-1385 ANO-C-2010-0670 ANO-1-2010-2242 ANO-C-201 0-i 486 ANO-C-2010-1353 ANO-C-2010-1959 ANO-C-2010-3025 ANO-C-201 0-21 02 ANO-1-2010-1330 ANO-2-2010-1385 ANO-C-2010-1446 ANO-1-201 0-281 0 ANO-C-2009-1332 ANO-C-2009-0666 ANO-C-2009-0175 ANO-C-2010-0943 ANO-2-2005-1307 ANO-C-2010-1964 ANO-C-2010-2114 ANO-C-2010-2140 ANO-1-2009-1193 ANO-C-2009-1342 ANO-1-2010-2127 ANO-2-2010-1203 ANO-2-2009-1180 ANO-2-2009-1327 ANO-2-2009-2991 ANO-2-2009-3293 ANO-C-2010-1178 ANO-C-2010-0371 ANO-1-2010-2218 ANO-C-2010-1482 ANO-2-2009-1157 ANO-2-2005-2151 ANO-1-2010-3763 ANO-C-2006-0852 ANO-1-2010-1149 ANO-1-2010-1316 ANO-1-2010-1982 ANO-1-20 10-2522 ANO-C-2010-1133 ANO-C-2009-0613 ANO-C-2009-0151 ANO-C-2010-0792 ANO-1-2009-1051 ANO-1-2009-1111 ANO-1-2010-0364 ANO-1-2010-0501 ANO-C-201 0-1 048 ANO-C-2010-1793 ANO-C-2010-2176 ANO-C-2010-0450 ANO-2-2010-0896 ANO-2-2010-2318 ANO-1-2009-0357 ANO-C-2009-1400 ANO-1-2009-0872 ANO-1-2009-0984 ANO-1-2009-0993 ANO-2-2009-1573 ANO-C-2006-0852 ANO-C-2002-0921 HQN-2011-0126 ANO-1-2009-0655 ANO-C-2010-0808 ANO-C-2009-2599 ANO-C-2009-3916 ANO-C-2009-2658 ANO-C-2009-0755 ANO-C-2009-1506 ANO-1-2009-1578 ANO-C-201 0-1 066 ANO-1-2009-0695 ANO-1-2009-0880 ANO-1-2009-2144 ANO-1-2009-2273 ANO-C-2010-0693 ANO-1-2010-1050 ANO-C-2009-2562 ANO-C-2009-2561 ANO-C-2010-0691 ANO-C-2010-1048 ANO-C-2010-1140 ANO-C-201 0-181 0 ANO-C-2009-0649 ANO-C-2009-1417 ANO-1-2009-0178 ANO-C-20 10-1062 ANO-C-2010-0536 ANO-C-2009-0025 ANO-C-2010-0802 ANO-1-2009-0794 ANO-C-2009-04 7 4 ANO-2-2009-2332 ANO-C-2009-2571 ANO-C-2010-0691 ANO-2-2010-0470 ANO-C-2009-2664 ANO-1-2011-0268 ANO-2-2011-0425 ANO-C-2010-0452 ANO-2-2009-0491 ANO-2-2009-1492 ANO-2-2008-2076 AI\\IA -1
'"){'\\{'\\{'\\ {'\\A'")O ANO-C-2009-1582 ANO-1-2009-0449 1\\ II\\. II"""\\.
A I"'\\r.r.r. r.,...-, A
,\\I 'IV-I -tt..VV;:;-V"Ttt..U KI'IV-I-LUU:;1-UO f <+
ANO-C-2010-0415 ANO-C-2009-0012 ANO-C-2010-0715 ANO-1-2009-0650 A - 5-Attachment
1-0412 0-0405
-1 ANO-2-2009-0352 ANO-1-2009-0257 ANO-2-2009-0332 ANO-C-2009-0262 ANO-C-2009-0331 ANO-C-2009-1355 ANO-1-2009-0029 ANO-C-2010-0986 ANO-1-2009-0318 ANO-1-2010-2887 ANO-1-2010-2957 ANO-C-2010-1965 ANO-1-2010-0304 ANO-1-2008-0544 ANO-2-2009-3019 ANO-1-2010-2102 ANO-C-2010-0272 ANO-C-2009-0007 ANO-C-2010-0549 ANO-2-2009-0-141 ANO-C-2010-0248 ANO-C-2009-0005 ANO 2-2009-0025 ANO-2-2009-0111 ANO-C-2010-0246 ANO-C-2009-2372 ANO-1-2010-0317 ANO-C-2010-1475 ANO-1-2009-0225 ANO-2-2009-0658 ANO-C-2010-1351 ANO-C-2010-1352 ANO-1-2009-0216 ANO-1-2009-0337 ANO-2-2010-2241 ANO-2-2010-2379 ANO-2-2010-0189 ANO-2-2010-1487 ANO-2-2009-2671 ANO-2-2010-0120 ANO-C-2010-0148 ANO-1-2010-2859 ANO-C-2009-1840 ANO-2-2009-3831 ANO-C-2010-0057 ANO-C-2010-2920 ANO-1-2010-0127 ANO-1-2010-0389 ANO-C-2010-0013 ANO-2-2010-0944 ANO-2-2009-2031 ANO-1-2009-2089 ANO-C-2010-2112 Work Orders 73525 136213 156344 130289 191737 51511439 136660 219604 212805 218613 174198 218614 138588 132593 174187 129845 129845 134538 174193 155887 52191209 52036682 52206839-1 00178928 51676088 50240094 00252784-01 00256586 00210819 50013499 50013514 00240431 00226754 00215986 00220801 Audits and Surveillances NQ-2009-0014 NQ-2010-014 NQ-2010-013 NQ-2009-023 NQ-2009-0039 NQ-2009-010 NQ-2009-030 NQ-2010-001 L O-AL 0-2008-00080 LO-ALO-2010-00001 LO-ALO-2008-00001 L O-AL 0-2008-00096 LO-ALO-2009-00018 LO-ALO-2009-00029 I (l_lll (l_ ')nnaJ)nn~ 1 I (l_lll (l_')nnannnAt:::
__ I
\\10-'-"
"-,,",'oJV vvvv I
...... '-' I
'\\..........., -e-VVv-VVV""'Tv L O-AL 0-2009-00061 LO-ALO-2009-00062 L O-AL 0-2009-00065 A-6-Attachment
O!;2erating EX!;2erience GE-TIL-1631 CR-NOE-2009-0479 GE-TIL-1656-A2-ANO-OOOi LO-NOE-2009-357 NRC RIS 2001-09 Miscellaneous Number EP-006 LO-NOE-2009-0090 CR-NOE-2009-0206 CR-NOE-2009-0382 WH-TB-1 0-1-A2-WH-TB-09-4-R 1-A2-WH-TB-09-4-R 1-A2-ANO-OOOi ANO-0001 ANO-0002 WH-TB-1 0-4-A2-WH-TB-1 0-4-A2-LO-NOE-2009-0136 ANO-OOOi ANO-0002 LO-NOE-2009-099 LO-NOE-2009-361 ER-ANO-2004-0735 Title Revision ANO 2010 Second Quarter Oversight Report ANO Emergency Planning Desk Guide Drill/Exercise Manual Addendum
FLP-MMBA-FASNR Fasteners, Torque, Gaskets o
o EC-23566 EC-25759 EC-19590 980020E201 STM 1-42 STM 2-42 Defeat TS-6060 on VCH-4B by Turning to the Off Position ANO-1 VCH-4A14B Trip Hardening Install Blocking Diode on DC Input of Unit 1 and Unit 2 Safety Related Inverters Engineering Request Service & Auxiliary Cooling Water (Unit 1)
Service Water & Auxiliary Cooling Water Systems (Unit 2)
A - 7-o o
o
34 Attachment
Request 5,
Biennial Problem Identification and Resolution Inspection -
Arkansas Nuclear One Inspection Report Number 2011006 This inspection will cover the period from February 20, 2009 to January 15, 2011. All requested information should be limited to this period unless otherwise specified. To the extent possible, the requested information should be provided electronically in Adobe PDF or Microsoft Office format. Lists of documents should be provided in Microsoft Excel or a similar sortable format.
A supplemental information request will likely be sent during the week of January 10, 2011, or before.
Please provide the following no later than December 30, 2010:
1.
Document Lists Note: for these summary lists, please include the document/reference number, the document title or a description of the issue, initiation date, and current status.
a.
Summary list of all corrective action documents related to significant conditions adverse to quality that were opened, closed, or evaluated during the period b.
Summary list of all corrective action documents related to conditions adverse to quality that were opened or closed during the period c.
Summary lists of operator workarounds, engineering review requests and/or operability evaluations, temporary modifications, and control room and safety system deficiencies opened, closed, or evaluated during the period d.
Summary list of plant safety issues raised or addressed by the Employee Concerns Program (or equivalent)
e.
Summary list of all Apparent Cause Evaluations completed during the period f.
Summary list of all Root Cause Evaluations planned or in progress but not complete at the end of the period 2.
Full Documents, with Attachments a.
Root Cause Evaluations completed during the period b.
Quality assurance audits performed during the period c.
All audits/surveillances performed during the period of the Corrective Action Program, of individual corrective actions, and of cause evaluations d.
Corrective action activity reports, functional area self-assessments, and non-f\\JRC third party assessments completed during the period (do not include I~~PO assessments)
A-8-Attachment
e.
generated during the following:
i.
NCV's and Violations issued ii.
submitted f.
Corrective action documents generated for the following (for those that were evaluated but determined not to be applicable, provide a summary list):
i.
NRC information Notices, Buiietins, and Generic Letters issued or evaluated during the period ii.
Part 21 reports issued or evaluated during the period iii.
Vendor safety information letters (or equivalent) issued or evaluated during the period iv.
Other external events and/or Operating Experience evaluated for applicability during the period g.
Corrective action documents generated for the following:
i.
Emergency planning drills and tabletop exercises performed during the period ii.
Maintenance preventable functional failures which occurred or were evaluated during the period iii.
Adverse trends in equipment, processes, procedures, or programs which were evaiuated during the period iv.
Action items generated or addressed by plant safety review committees during the period 3.
Logs and Reports a.
Corrective action performance trending/tracking information generated during the period and broken down by functional organization b.
Corrective action effectiveness review reports generated during the period c.
Current system health reports or similar information d.
Radiation protection event logs during the period e.
Security event logs and security incidents during the period (sensitive information can be provided by hard copy during first week on site)
f.
Employee Concern Program (or equivalent) logs (sensitive information can be provided by hard copy during first week on site)
A-9-Attachment
4.
5.
g.
requests training improvements, and simulator a.
Corrective action program procedures, to include initiation and evaluation procedures, operability determination procedures, apparent and root cause evaluation/determination procedures, and any other procedures which implement the corrective action program.
b.
Quality Assurance program procedures c.
Employee Concerns Program (or equivalent) procedures d.
Procedures which implement/maintain a Safety Conscious Work Environment Other a.
List of risk significant components and systems b.
Organization charts for plant staff and long-term/permanent contractors A - 10-Attachment