IR 05000313/2015002

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Revised NRC Inspection Report 05000313/2015002 and 05000368/2015002
ML16232A624
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 08/19/2016
From: O'Keefe N
NRC/RGN-IV/DRP/RPB-E
To: Warren C
Entergy Operations
O'Keefe C
References
EA-15-194 IR 2015002
Download: ML16232A624 (45)


Text

ust 19, 2016

SUBJECT:

ARKANSAS NUCLEAR ONE - REVISED NRC INSPECTION REPORT 05000313/2015002 and 05000368/2015002

Dear Mr. Warren:

On September 3, 2015, Entergy Operations, Inc. (Entergy), the licensee for Arkansas Nuclear One (ANO), provided a response to the U.S. Nuclear Regulatory Commissions (NRCs)

Inspection Report 05000313/2015002 and 05000368/2015002 (ML15218A371) issued on August 5, 2015. In this letter, Entergy disagreed with non-cited violation (NCV) 05000313, 368/2015002-04, Failure to Perform Testing of Diesel Fuel Oil Transfer Piping. The response letter is docketed under ML15246A591. Specifically, Entergy believes that the NCV inappropriately applied the same regulation (i.e. 10 CFR 50.55a(g)(1)) to both ANO units without distinguishing between the different licensing bases for the two units based on construction permit dates.

On October 8, 2015, the NRC acknowledged receipt of your letter (ML15282A338) and informed you that the staff would review your basis for contesting the NCV and provide the results of our evaluation by written response.

The NRC conducted a detailed review of your response and provided our conclusions by Letter, dated August 19, 2016 (ML16232A618). After consideration of the bases for your contention of the NCV, the NRC has concluded that the violation is better characterized under 10 CFR Part 50, Appendix B, Criterion XI, Test Control, related to the failure to establish and maintain an adequate testing program for the fuel oil transfer piping for ANO, Units 1 and 2 without referring to 10 CFR 50.55a(g)(1) or (g)(4). As a result, the NRC is revising the non-cited violation documented in Section 1R08b.2 of the enclosed Inspection Report 05000313/2015002, 05000368/2015002. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Neil OKeefe, Chief Project Branch E Division of Reactor Projects Docket Nos. 50-313; 50-368 License Nos. DRP-51; NPF-6

Enclosure:

Inspection Report 05000313/2015002 and 05000368/2015002 w/Attachment:

1. Supplemental Information 2. Request for Information

REGION IV==

Docket: 05000313; 05000368 License: DPR-51; NPF-6 Report: 05000313/2015002; 05000368/2015002 Licensee: Entergy Operations Inc.

Facility: Arkansas Nuclear One, Units 1 and 2 Location: Junction of Hwy. 64 West and Hwy. 333 South Russellville, Arkansas Dates: April 1 through June 30, 2015 Inspectors: B. Tindell, Senior Resident Inspector M. Young, Resident Inspector L. Carson, II, Senior Health Physicist J. Drake, Senior Reactor Inspector Z. Hollcraft, Reactor Operations Engineer M. Phalen, Senior Health Physicist M. Williams, Reactor Inspector Approved Neil OKeefe By: Chief, Project Branch E Division of Reactor Projects-1- Enclosure

SUMMARY

IR 05000313/2015002; 05000368/2015002; 04/01/2015 - 06/30/2015; Arkansas Nuclear One,

Units 1 and 2, Integrated Inspection Report; Adverse Weather Protection, Flood Protection Measures, Inservice Inspection Activities.

The inspection activities described in this report were performed between April 1, 2015, and June 30, 2015, by the resident inspectors at Arkansas Nuclear One and inspectors from the NRCs Region IV office and other NRC offices. Four findings of very low safety significance (Green) are documented in this report. Three of these findings involved violations of NRC requirements. The significance of inspection findings is indicated by their color (Green, White,

Yellow, or Red), which is determined using Inspection Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects within the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

Cornerstone: Initiating Events

Green.

The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B,

Criterion V, Instructions, Procedures, & Drawings, for the failure to establish appropriate procedures for preparations for severe weather. Specifically, inspectors observed that the licensee failed to ensure that all outside areas were inspected in order to secure material prior to severe weather, to reduce the probability of light material missile damage on plant equipment. The licensee concluded that the assignment of responsibilities was unclear in Procedure EN-FAP-EP-010, Severe Weather Response, Revision 1, leading to confusion among the two operating crews. This issue was entered into the licensees corrective action program as Condition Reports CR-ANO-C-2015-00854 and CR-ANO-C-2015-00859.

The failure to have a procedure to ensure that all outside areas would be inspected in order to secure loose material prior to the arrival of severe weather, to reduce the probability of light material missile damage on plant equipment was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedure quality attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, during severe weather, unsecured material could become a missile that impacts equipment and upsets plant stability. Using NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, the inspectors determined that the finding had very low safety significance (Green) because it did not represent an actual reactor trip and the loss of mitigation equipment. This finding has a human performance cross-cutting aspect associated with work management, in that the organization failed to implement a process of planning, controlling, and executing work activities, including coordination with different groups or job activities. Specifically, only one crew performed the required inspections when severe weather had been forecast since the procedure in use did not clearly assign responsibilities to both operating crews [H.5]. (Section 1R01)

Green.

The inspectors reviewed a self-revealing finding involving failure to verify that the proper material was installed in the plant during initial construction of the Unit 2 reactor coolant system (RCS) sample system. Specifically, failure to use the correct material resulted in two through-wall leaks in the supply line to the 2E30 cooler for the RCS sample system. The licensee removed the components with the incorrect material and installed components of the correct material. This issue was entered into the licensees corrective action program as Condition Report CR-ANO-C-2014-01800.

The failure to verify the correct materials were installed in the plant is a performance deficiency. This performance deficiency is more than minor because it is associated with the equipment performance attribute of the Initiating Events Cornerstone and affects the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as during power operations.

Specifically, failure to install the correct material resulted in failure of the RCS sample system and the inability to meet technical specification requirements for determining dose equivalent Xenon-133. Using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 1,

Initiating Event Screening Questions, the inspectors determined the finding is of very low safety significance (Green) because the transient initiator did not cause a reactor trip and the loss of mitigating equipment. This finding has not been assigned a cross-cutting aspect because the incorrect material was installed during initial construction, and is not indicative of current plant performance. (Section 1R08.1)

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green non-cited violation of 10 CFR Part 50,

Appendix B, Criterion III, Design Control, for the failure to select and review equipment for suitability of application that is essential to the safety-related function of Unit 2 motor control center (MCC) 2B-52. Specifically, the licensee failed to ensure that the safety-related electrical equipment inside the MCC was adequately protected from water spray in the event of a failure of overhead non-seismic category 1 pipes, in accordance with the safety analysis report. Inspectors identified that the installed spray curtain only protected the front of the cabinet, while a cooling water pipe that could break during a seismic event was located directly above the length of the MCC. This issue was entered into the licensees corrective action program as Condition Report CR-ANO-C-2015-01342.

The failure to protect Unit 2 MCC 2B-52 from possible spray of overhead non-seismic category 1 pipes by installing a spray shield in accordance with the safety analysis report was a performance deficiency. The performance deficiency was more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the performance deficiency could result in failure of one train of essential safety features during a seismic event, such as exhaust fans for the emergency diesel generators, containment spray isolation valves, and high pressure safety injection isolation valves. Using NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, the inspectors determined to require a detailed risk evaluation because the finding involved degradation of equipment specifically designed to mitigate a seismic event and could degrade one train of a system that supports a risk-significant function. A senior reactor analyst performed the detailed risk evaluation and estimated the change to the core damage frequency was 3.8E-8/year (Green). The dominant core damage sequences included seismically induced losses of offsite power. This finding did not have a cross-cutting aspect associated with it because the most significant contributing cause was not indicative of present performance. Specifically, the condition had existed since plant construction, with no recent substantial opportunities to identify the issue. (Section 1R06)

Green.

The inspectors identified a Green non-cited violation of 10 CFR Part 50,

Appendix B, Criterion XI, Test Control. Specifically, the licensee did not establish testing requirements and acceptance limits to detect degradation of the fuel oil piping, which could result in the piping being rendered inoperable and unable to meet its safety-related function due to undetected cracks or other types of degradation. The licensee entered this issue into their corrective action program as Condition Report CR-ANO-2-2015-01092.

The licensees failure to perform adequate testing of the fuel oil piping was a performance deficiency. The performance deficiency was determined to be more than minor because it is associated with the protection against external factors attribute of the Mitigating Systems Cornerstone, and adversely affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to perform examinations required to demonstrate that the piping would perform its intended function during design basis seismic events, and therefore maintain the ability to supply fuel to the emergency diesel generators. The inspectors evaluated the finding using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems, the inspectors determined the finding is of very low safety significance (Green) because the finding did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic initiating event. The finding has a human-performance cross-cutting aspect associated with conservative bias because the licensee did not use decision making-practices that emphasized prudent choices over those that were simply allowable. Specifically, during the buried piping initiative inspections that were completed in August 2013, the licensee failed to identify that the condition of the safety-related piping had never been evaluated and was being treated as a run to failure component [H.14]. (Section 1R08.2)

PLANT STATUS

Unit 1 operated at 100 percent power for the entire inspection period.

Unit 2 operated at 100 percent power for the entire inspection period.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Summer Readiness for Offsite and Alternate AC Power Systems

a. Inspection Scope

On May 1, 2015, the inspectors completed an inspection of the stations off-site and alternate-ac power systems. The inspectors inspected the material condition of these systems, including transformers and other switchyard equipment to verify that plant features and procedures were appropriate for operation and continued availability of offsite and alternate-ac power systems. The inspectors reviewed outstanding work orders and open condition reports for these systems. The inspectors walked down the switchyard to observe the material condition of equipment providing off-site power sources.

The inspectors verified that the licensees procedures included appropriate measures to monitor and maintain availability and reliability of the off-site and alternate-ac power systems.

These activities constituted one sample of summer readiness of off-site and alternate-ac power systems, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

On March 26, 2015, the inspectors completed an inspection of the stations readiness for impending adverse weather conditions. The inspectors reviewed plant design features, the licensees procedures to respond to tornadoes and high winds, and the licensees implementation of these procedures. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant.

These activities constituted one sample of readiness for impending adverse weather conditions, as defined in Inspection Procedure 71111.01.

b. Findings

Introduction.

The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to establish appropriate procedures for severe weather preparations. Specifically, the licensee failed to ensure that all outside areas were toured in order to secure material prior to severe weather, to reduce the probability of light material missile damage on plant equipment.

Description.

The inspectors reviewed Procedures OP-1203.025, Natural Emergencies, Revision 053, OP-2203.008, Natural Emergencies, Revision 036, and Entergy Procedure EN-FAP-EP-010, Severe Weather Response, Revision 001. Unit 1 Procedure OP-1203.025, Section 2, Predicted Severe Weather, states, Notify Unit 2 and dispatch Unit 1 personnel to perform walkdowns in the protected area identifying potential missile hazards using Severe Weather Missile Hazard Reduction Standard, 7.15 of Procedure EN-FAP-EP-010 as a guide to determine whether materials outside the plant require resolution. Procedure EN-FAP-EP-010, 7.15, Severe Weather Missile Hazard Reduction Standard, stated, in part, that the purpose was to reduce the chances of light material missile damage on plant facilities.

On March 25, 2015, the National Weather Service issued a severe thunderstorm watch for Pope County. The inspectors reported to the control room to observe the operators severe weather preparations. The inspectors observed that the Unit 1 operator did not tour Unit 2 areas, and that no Unit 2 operator had been dispatched. The inspectors notified the licensee and operators subsequently walked down Unit 2 areas.

The inspectors also performed a walkdown of the turbine building roof because the procedure did not explicitly require a walkdown of the area, and it is physically above high voltage lines and transformers in the yard. The inspectors discovered debris that could be potential missile hazards. The licensee subsequently secured the loose items and documented the concern in Condition Report CR-ANO-C-2015-00859.

The inspectors noted that the procedures failed to provide clear guidance for either the Unit 1 operator to walk down all areas, or to dispatch a Unit 2 operator. Therefore, the inspectors concluded that the procedure was inadequate to ensure that all outside areas were toured in order to secure material prior to severe weather, and in this case did not meet the purpose statement of Procedure EN-FAP-EP-010, Attachment 7.15, referenced above. The licensee documented the concern in Condition Report CR-ANO-C-2015-00854 and initiated a standing order to clarify adequate preparations between both units until a procedure change could be completed.

Analysis.

The failure to have an adequate procedure to ensure that all outside areas were inspected in order to secure material prior to severe weather to reduce the probability of light material missile damage on plant equipment, in accordance with Procedure EN-FAP-EP-010, Severe Weather Response, Revision 1, was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedure quality attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, during severe weather, unsecured material could become a missile that impacts equipment and upsets plant stability. Using NRC Inspection Manual Chapter 0609.04, Initial Characterization of Findings, effective July 1, 2012, and NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, effective July 1, 2012, the inspectors determined that the finding had very low safety significance (Green) because it did not represent an actual reactor trip or loss of mitigation equipment. This finding has a human performance cross-cutting aspect associated with work management, in that the organization failed to implement a process of planning, controlling, and executing work activities, including coordination with different groups or job activities.

Specifically, only one crew performed the required inspections when severe weather had been forecast since the procedure in use did not clearly assign responsibilities to both operating crews [H.5].

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion V, Instruction, Procedures, and Drawings, states, in part, that activities affecting quality shall be prescribed by procedures of a type appropriate to the circumstance. Contrary to the above, as of March 25, 2015, the procedure for severe weather preparations, an activity affecting quality, was not appropriate to the circumstance. Specifically, Procedure EN-FAP-EP010, Severe Weather Response, Revision 1, was unclear in assigning responsibility for inspecting the entire site for potential missile hazards. The licensee initiated a standing order to establish adequate preparations for both units until a procedure change could be completed. This violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy because it was of very low safety significance (Green) and it was entered into the licensees corrective action program as Condition Reports CR-ANO-C-2015-00854 and CR-ANO-C-2015-00859. (NCV 05000313, 368/2015002-01; Inadequate Procedure for Severe Weather Preparation)

1R04 Equipment Alignment

.1 Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walk-downs of the following risk-significant systems:

  • May 5, 2015, Unit 2, turbine driven emergency feedwater train while the motor driven emergency feedwater train was out of service for maintenance
  • May 27, 2015, Unit 1, electric driven fire water pump while the diesel driven fire water pump was out of service for maintenance
  • June 18, 2015, Unit 2, high pressure safety injection train A while train B was out of service for testing The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration.

These activities constituted three partial system walk-down samples as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on four plant areas important to safety:

  • April 15, 2015, Unit 2, Fire Zone 2091-BB, north electrical equipment room
  • April 15, 2015, Unit 2, Fire Zone 2099-W, west dc equipment room
  • May 1, 2015, Unit 2, Fire Zone Intake, intake structure
  • June 10, 2015, Unit 1, Fire Zones 86-G and 87-H, emergency diesel generators For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.

These activities constituted four quarterly inspection samples, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

a. Inspection Scope

On April 9, 2015, the inspectors completed an inspection of the stations ability to mitigate flooding due to internal causes. After reviewing the licensees flooding analysis, the inspectors chose two plant areas containing risk-significant structures, systems, and components that were susceptible to flooding:

  • Unit 1 decay heat watertight vaults
  • Unit 2 upper and lower electrical penetration rooms and elevation 335 ft. corridor The inspectors reviewed plant design features and licensee procedures for coping with internal flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether operator actions credited for flood mitigation could be successfully accomplished.

The inspectors reviewed the circumstances surrounding the licensees discovery that a flood protection seal had been installed in the incorrect location to provide flood protection for the Unit 2 decay heat removal vaults. The seal was installed as part of corrective actions to address Yellow finding 2014009-01. This issue was documented in Condition Report CR-ANO-2-2015-00716 and was dispositioned as an NCV in Inspection Report 2015008.

These activities constitute completion of two flood protection measures samples, as defined in Inspection Procedure 71111.06.

b. Findings

Introduction.

The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the failure to select and review equipment for suitability of application that is essential to the safety-related function of Unit 2 motor control center (MCC) 2B-52. Specifically, the licensee failed to ensure that the safety-related electrical equipment inside the MCC was adequately protected from water spray in the event of a failure of overhead non-seismic category 1 pipes in accordance with the safety analysis report.

Description.

During internal flooding walkdown sample selection, the inspectors reviewed the Unit 2 safety analysis report, Amendment 23. Section 3.6.4.3.3.4, stated, in part, that one engineered safety features MCC is located in the passageway near the spent resin storage tank. Several low-energy non-seismic Category 1 piping systems pass above this MCC. To protect the MCC from possible spray from these pipes, a spray shield has been constructed over the MCC.

On April 15, 2015, the inspectors performed a walkdown of the above-described MCC 2B-52 and spray shield. The inspectors noted that the MCC powered red train mitigating equipment needed to mitigate seismic events, including emergency diesel generator exhaust fans, containment spray isolation valves, and high pressure safety injection isolation valves. The inspectors also noted that the spray shield was installed vertically in front of the cabinet, and determined that the configuration would not protect the internal equipment from postulated overhead water spray from failed piping.

Therefore, the inspectors concluded that the licensee failed to install the spray shield in accordance with the safety analysis report, and the mitigation equipment powered by 2B-52 may fail during a seismic event due to the lack of a spray shield. The licensee initiated Condition Report CR-ANO-C-2015-01342 to document the inspectors concerns. The licensee also evaluated the condition to ensure that the overhead pipes, while not fully qualified for seismic conditions, were sufficiently rugged and therefore unlikely to break during a seismic event.

The inspectors determined that the condition had existed since plant construction, with no recent substantial opportunities to identify the issue.

Analysis.

The failure to protect Unit 2 MCC 2B-52 from possible spray of overhead non-seismic category 1 pipes by installing a spray shield in accordance with the safety analysis report was a performance deficiency. The performance deficiency was more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the performance deficiency could result in failure of one train of essential safety features during a seismic event, such as exhaust fans for the emergency diesel generators, containment spray isolation valves, and high pressure safety injection isolation valves. Using NRC Inspection Manual Chapter 0609.04, Initial Characterization of Findings, effective July 1, 2012, and NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, effective July 1, 2012, the inspectors determined the finding required a detailed risk evaluation because the finding involved degradation of equipment specifically designed to mitigate a seismic event and could degrade one train of a system that supports a risk-significant function. A senior reactor analyst performed the detailed risk evaluation and estimated the change to the core damage frequency was 3.8E-8/year (Green). The dominant core damage sequences included seismically induced losses of offsite power. See Attachment 2 for the detailed risk evaluation.

This finding did not have a cross-cutting aspect associated with it because the most significant contributing cause was not indicative of present performance. Specifically, the condition had existed since plant construction, with no recent substantial opportunities to identify the issue.

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, states, in part, that for those structures, systems, and components (SSCs) to which this appendix applies, measures shall be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the SSCs. Contrary to the above, from construction until April 15, 2015, for quality-related components associated with Unit 2 MCC 2B-52, to which 10 CFR Part 50, Appendix B applies, the licensee failed to select and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related function of the component. Specifically, the licensee failed to ensure that the safety-related electrical equipment inside the MCC was adequately protected from water spray in the event of a failure of overhead non-seismic category 1 pipes. The licensee evaluated the condition to ensure that the overhead pipes, while not fully qualified for seismic conditions, were sufficiently rugged and therefore unlikely to break during a seismic event. This violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy because it was of very low safety significance (Green) and it was entered into the licensees corrective action program as Condition Report CR-ANO-C-2015-01342. (NCV 05000368/2015002-02; Failure to Protect Motor Control Center from Potential Pipe Spray)

1R08 Inservice Inspection Activities

a. Inspection Scope

This inspection was focused on resolving two Unresolved Items (URIs) opened during the performance of inspection IP 71111.08, Inservice Inspection Activities, documented in NRC Inspection Report 05000313; 368/2014003. The inspectors reviewed additional licensing basis information provided by the licensee, as well as industry standards and regulatory guidance. The information below documents the resolution of these two URIs.

b. Findings

.1 Failure to Verify Material Properties Prior to Installation

Introduction.

The inspectors reviewed a self-revealing Green finding involving failure to verify that the proper material was installed in the plant during construction of the Unit 2 reactor coolant system (RCS) sample system.

Description.

On February 3, 2014, two through-wall leaks in the supply line to the reactor coolant sample cooler, 2E30, were identified. The 2E30 heat exchanger is used to cool samples obtained from the reactor coolant system. These samples are used to verify the reactor coolant system dose equivalent Xenon-133 specific activity meets Technical Specification 4.4.8.1, Surveillance for Dose Equivalent Xenon (DEX), which is required once per 7 days to ensure the acceptability of the system for continued operation. Follow-up review by the licensee determined that the RCS sample system had not been built as designed. Design Drawing M-2014-2 specified that ASME SA-479, Type 304, stainless steel be used in the components. The components were actually made of carbon steel. Use of the wrong material resulted in through-wall corrosion of the piping and the reactor coolant system sample system being declared inoperable.

Analysis.

The failure to use the correct materials in the Unit 2 reactor coolant sampling system as specified by design drawings is a performance deficiency. The finding is more than minor because it is associated with the equipment performance attribute of the initiating events cornerstone and adversely affects the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, failure to verify the correct material prior to installation resulted in the failure of the RCS sample system; the inability to sample the reactor coolant for activity could upset plant stability by necessitating an unplanned shutdown as required by technical specifications. Using Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, dated June 19, 2012, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 1, Initiating Events Screening Questions, the inspectors determined that the finding is of very low safety significance (Green) because the finding did not result in a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of a trip to a stable shutdown condition. This finding has not been assigned a cross-cutting aspect because the incorrect material was used during initial construction, and thus not indicative of current plant performance.

Enforcement.

This finding did not involve enforcement action because no regulatory requirements were violated. This issue was entered into licensees corrective action program as Condition Report CR-ANO-C-2015-01091. The faulted component was replaced with a component of the correct material. (FIN 05000368/2015002-03; Failure to Verify Material Properties Prior to Installation)

.2 Failure to Perform Adequate Testing of Diesel Fuel Oil Transfer Piping

Introduction.

The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, for the licensees failure to establish and maintain an adequate testing program for the fuel oil transfer piping for Units 1 and 2.

Specifically, the licensee did not establish testing requirements to detect degradation of the fuel oil piping between the fuel oil storage tanks and the emergency diesel generator day tanks.

Description.

During performance of TI 2515/182, Review of the Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks, the inspectors determined that the fuel oil transfer piping was not included in the licensees inservice inspection program. During performance of IP 71111.08, Inservice Inspection Activities, in May 2014, the inspectors further determined that the licensee was not performing inspections/testing to ensure the fuel oil piping would perform satisfactorily in service.

Through document review, the inspectors determined that the fuel oil transfer piping for Units 1 and 2 was safety-related, seismic Class 1 piping that provided the ability to transfer fuel oil from the fuel oil storage tanks to the emergency diesel generator day tanks. The fuel oil transfer systems for both units were designed and built to ASME Code B31.1.0 requirements. It was noted by the inspectors that the requirements of 10 CFR Part 50, Appendix B, were applicable to the fuel oil transfer piping because the requirements apply to all activities affecting the safety-related functions of structures, systems, and components. The inspectors also identified that the NRC has issued a number of guidance documents describing fuel oil storage and transfer systems and acceptable testing programs, including NUREG-75/087, Standard Review Plan, and Regulatory Guide 1.137, Fuel-Oil Systems for Standby Diesel Generators.

The licensee stated that Arkansas Nuclear Ones technical specifications required surveillance testing of the diesel generators and analysis of the fuel oil. The licensee further stated that, together with the aging management program, these surveillances provided adequate assurance that the fuel oil piping can perform its safety function. The NRC agrees that these measures ensure that fuel oil is flowing to the emergency diesel generators. However, they do not verify the structural integrity of the piping or whether the piping still meets the design requirements of B31.1 and Seismic Class 1.

Analysis.

The inspectors determined that the failure to perform adequate testing of the fuel oil piping is a performance deficiency. In accordance with Inspection Manual Chapter 0612, Appendix B, Issue Screening, the issue is more than minor because it is associated with the protection against external factors attribute of the Mitigating Systems Cornerstone, and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to perform examinations required to demonstrate that the piping can perform its intended function during design basis seismic events, and therefore maintain the ability to supply fuel to the emergency diesel generators. The inspectors evaluated the finding using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems. The inspectors determined the finding is of very low safety significance (Green) because the finding did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic initiating event. The finding has a cross-cutting aspect in the area of human performance, associated with conservative bias, because the licensee did not use decision making-practices that emphasized prudent choices over those that were simply allowable. Specifically, during the buried piping initiative inspections that were completed in August 2013, the licensee failed to identify that the condition of the safety-related piping had never been evaluated and was being treated as a run to failure component [H.14].

Enforcement.

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 SSCs 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. Contrary to the above, from initial commercial operations to the present, the licensee failed to establish an adequate test program to assure that all testing required to demonstrate that the fuel oil transfer piping will perform satisfactorily in service was identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Specifically, the licensee did not establish testing requirements and acceptance limits to detect degradation of the fuel oil piping, which could result in the piping being rendered inoperable and unable to meet its safety-related function due to undetected cracks or other types of degradation.

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, 368/2015002-04; Failure to Perform Testing of Diesel Fuel Oil Transfer Piping)

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On May 20, 2015, the inspectors observed Unit 2 simulator training for an operating crew. On June 17, 2015, the inspectors observed a Unit 1 simulator examination for an operating crew. The inspectors assessed the performance of the operators and the evaluators critique of their performance.

These activities constitute completion of two quarterly licensed operator requalification program samples, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

The inspectors observed the performance of on-shift licensed operators in the plants Unit 1 and Unit 2 main control rooms. The inspectors observed the operators performance of the following activities:

  • May 29, 2015, Unit 2, emergency diesel generator A surveillance In addition, the inspectors assessed the operators adherence to plant procedures, including conduct of operations procedure and other operations department policies.

These activities constitute completion of two quarterly licensed operator performance samples, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed two instances of degraded performance or condition of SSCs that were important to safety:

  • March 13, 2015, Unit 1, instrument air dryer supply line rupture
  • March 13, 2015, Unit 1, reactor building tendon grease leaks The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.

These activities constituted completion of two maintenance effectiveness samples, as defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed two risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:

  • May 6, 2015, Unit 1, loop 2 service water to intermediate cooling water cooler isolation valve, CV-3811, out of service
  • June 10, 2015, Unit 1, emergency diesel generator B out of service The inspectors verified that these risk assessments were timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.

The inspectors also observed portions of an emergent work activity that had the potential to cause an initiating event. On May 5, 2015, the inspectors observed Unit 2 motor control center 2B-53 maintenance due to high resistance connections that had the potential to cause a fault and/or fire.

The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected SSCs.

These activities constitute completion of two maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed seven operability determinations that the licensee performed for degraded or nonconforming SSCs:

  • April 7, 2015, Unit 1, operability determination for CV-1000 and CV-1009, electromatic relief valve block valve and pressurizer spray block valve environmental qualification configuration
  • May 27, 2015, Unit 2, operability determination for startup transformer 3 voltage regulator following damage to cabling from debris during high winds The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability of the degraded SSC.

These activities constitute completion of seven operability and functionality review samples, as defined in Inspection Procedure 71111.15.

b. Findings

No findings were identified.

1R18 Plant Modifications

a. Inspection Scope

On April 15, 2015, the inspectors reviewed a temporary modification to disable a degraded Unit 2 upper gripper coil for control element assembly 18.

The inspectors verified that the licensee had installed this temporary modification in accordance with technically adequate design documents. The inspectors verified that this modification did not adversely impact the operability or availability of affected SSCs.

The inspectors reviewed design documentation and plant procedures affected by the modification to verify the licensee maintained configuration control.

These activities constitute completion of one sample of temporary modifications, as defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed four post-maintenance testing activities that affected risk-significant SSCs:

  • April 24, 2015, Unit 2, motor control center 2B-35, following repair activities due to a fault
  • May 3, 2015, Unit 1, motor control center B-33, following preventative maintenance
  • May 6, 2015, Unit 1, loop 2 service water to intermediate cooling water cooler isolation valve CV-3811, following emergent maintenance The inspectors reviewed licensing- and design-basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.

These activities constitute completion of four post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed seven risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the SSCs were capable of performing their safety functions:

Inservice tests:

  • June 19, 2015, Unit 2, high pressure safety injection train B pump inservice test Reactor coolant system leak detection tests:
  • April 23, 2015, Unit 1, penetration room ventilation system surveillance test
  • May 29, 2015, Unit 2, emergency diesel generator A monthly surveillance The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.

These activities constitute completion of seven surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation

a. Inspection Scope

On June 17, 2015, the inspectors observed simulator-based licensed operator requalification training that included implementation of the licensees emergency plan.

The inspectors verified that the licensees emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the evaluators and entered into the corrective action program for resolution.

These activities constitute completion of one training observation sample, as defined in Inspection Procedure 71114.06.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS2 Occupational ALARA Planning and Controls

a. Inspection Scope

The inspectors assessed licensee performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). During the inspection, the inspectors interviewed licensee personnel and reviewed licensee performance in the following areas:

  • Site-specific ALARA procedures and collective exposure history, including the current 3-year rolling average, site-specific trends in collective exposures, and source-term measurements
  • ALARA work activity evaluations/post-job reviews, exposure estimates, and exposure mitigation requirements
  • The methodology for estimating work activity exposures, the intended dose outcome, the accuracy of dose rate and man-hour estimates, and intended versus actual work activity doses and the reasons for any inconsistencies
  • Records detailing the historical trends and current status of tracked plant source terms and contingency plans for expected changes in the source term due to changes in plant fuel performance issues or changes in plant primary chemistry
  • Radiation worker and radiation protection technician performance during work activities in radiation areas, airborne radioactivity areas, or high radiation areas
  • Audits, self-assessments, and corrective action documents related to ALARA planning and controls since the last inspection These activities constitute completion of one sample of occupational ALARA planning and controls as defined in Inspection Procedure 71124.02.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

a. Inspection Scope

The inspectors evaluated the accuracy and operability of the licensees personnel monitoring equipment, verified the accuracy and effectiveness of the licensees methods for determining total effective dose equivalent, and verified that the licensee was appropriately monitoring occupational dose. The inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas:

  • External dosimetry accreditation, storage, issue, use, and processing of active and passive dosimeters
  • The technical competency and adequacy of the licensees internal dosimetry program
  • Adequacy of the dosimetry program for special dosimetry situations such as declared pregnant workers, multiple dosimetry placement, and neutron dose assessment
  • Audits, self-assessments, and corrective action documents related to dose assessment since the last inspection These activities constitute completion of one sample of occupational dose assessment as defined in Inspection Procedure 71124.04.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation (71124.08) Shipment Preparation (02.05)

a. Inspection Scope

The inspectors observed shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and licensee verification of shipment readiness. The inspectors assessed whether the requirements of applicable transport cask certificate of compliance had been met. The inspectors evaluated whether the receiving licensee was authorized to receive the shipment packages. The inspectors evaluated whether the licensees procedures for cask loading and closure procedures were consistent with the vendors current approved procedures.

These inspection activities supplement those documented in Inspection Report 05000313/2015002 and constitute sample as defined in IP 71124.08-05.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security

4OA1 Performance Indicator Verification

.1 Safety System Functional Failures (MS05)

a. Inspection Scope

For the period of April 1, 2014, through March 31, 2015, the inspectors reviewed licensee event reports (LERs), maintenance rule evaluations, and other records that could indicate whether safety system functional failures had occurred. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, and NUREG-1022, Event Reporting Guidelines: 10 CFR 50.72 and 50.73, Revision 3, to determine the accuracy of the data reported.

These activities constituted verification of the safety system functional failures performance indicator for Unit 1 and Unit 2, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Reactor Coolant System Specific Activity (BI01)

a. Inspection Scope

The inspectors reviewed the licensees Unit 1 and Unit 2 reactor coolant system chemistry sample analyses for the period of April 1, 2014, through March 31, 2015, to verify the accuracy and completeness of the reported data. The inspectors observed a chemistry technician obtain and analyze a Unit 1 and Unit 2 reactor coolant system sample on May 28, 2015. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the reactor coolant system specific activity performance indicator for Unit 1 and Unit 2, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.3 Reactor Coolant System Total Leakage (BI02)

a. Inspection Scope

The inspectors reviewed the licensees records of Unit 1 and Unit 2 reactor coolant system total leakage for the period of April 1, 2014, through March 31, 2015, to verify the accuracy and completeness of the reported data. The inspectors observed the performance of Unit 1 RCS leak detection surveillance procedure on May 29, 2015, and Unit 2 RCS leak detection surveillance procedure on May 28, 2015. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the reactor coolant system leakage performance indicator for Unit 1 and Unit 2, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Semiannual Trend Review

a. Inspection Scope

The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, and other documentation to identify trends that might indicate the existence of a more significant safety issue. The inspectors verified that the licensee was taking corrective actions to address identified adverse trends.

These activities constitute completion of one semiannual trend review sample, as defined in Inspection Procedure 71152.

b. Observations and Assessments Roof Leaks On April 1, 2015, Unit 2 MCC 2B-35 electrically shorted. The licensee evaluated the fault in Condition Report CR-ANO-2-2015-00902 and determined that a contributor to the fault was past water intrusion due to an overhead roof leak.

On May 4, 2015, the licensee identified that there was an adverse trend regarding roof leaks at the facility, including two auxiliary building leaks, nine turbine building leaks, a leak at the alternate ac diesel generator building, and radioactive waste building leaks.

Some of the roof leaks have been long term and now require large sections of the roof to be replaced to correct the leakage. The licensee documented the observation in Condition Report CR-ANO-C-2015-01390, and plans to fix the leaks.

The inspectors observed that the licensee has taken action to protect plant equipment from wetting, such as tarps. However, as evidenced by the MCC 2B-35 fault, the inspectors concluded that plant equipment was more susceptible to wetting and damage due to the number and duration of the roof leaks.

Alternate Ac Diesel Generator Ventilation The inspectors observed a negative trend related to ventilation equipment for the alternate ac diesel generator, a safety significant electrical supply for Units 1 and 2.

The inspectors observed that 2VSF-32, the electrical room cooler had tripped multiple times within the past year. The inspectors also observed that, as documented in Condition Report CR-ANO-C-2015-01729, it was very difficult for operators to diagnose that the coolers breaker had tripped, due to the breaker design. The electrical room exhaust fan, 2VEF-19, had been available each time that 2VSF-32 was out of service, so the diesel generator remained available. However, due to the increased unreliability and the difficulty of diagnosis, the inspectors concluded that there was an increased probability of concurrent out of service time for fans 2VSF-32 and 2VEF-19, which would cause diesel generator unavailability. The licensee documented the inspectors concern in Condition Report CR-ANO-C-2015-01935.

The inspectors observed that 2VEF-18, the diesel generator room exhaust fan, had also tripped multiple times within the past year. A second room exhaust fan, 2VEF-17, had been available each time that 2VEF-18 was out of service. If outside air temperature exceeds 92 degrees Fahrenheit with 2VEF-18 out of service and 2VEF-17 available, then the diesel generator would be unavailable. However, the inspectors observed that when 2VEF-18 was out of service, operators were not tracking outside air temperature to ensure that the diesel generator remained available. The inspectors reviewed actual temperature data for those periods and determined that the diesel generator remained available. The licensee documented the inspectors concern in Condition Report CR-ANO-C-2015-01770.

The licensee has addressed the equipment failures through the corrective action program and the maintenance rule program trends the ventilation equipment failures.

However, the inspectors concluded that the licensee had failed to identify and correct the human factors that contributed to reliability of the alternate ac diesel generator; namely, operator walkdowns to ensure standby equipment is available, and tracking degraded conditions to ensure the standby equipment remained available.

c. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion

.1 (Closed) Licensee Event Report 05000368/2014-004-00, Technical Specification 3.0.4

Violation due to a Mode Change with an Inoperable Emergency Feedwater Pump

a. Inspection Scope

Revision 01 of this licensee event report was reviewed and closed in NRC Inspection Report 05000368/2015001, Section 4OA3.3. No additional deficiencies were identified during review of Revision 00 of this licensee event report. This licensee event report is closed.

b. Findings

No findings were identified.

.2 Event Follow-up for Unirradiated Nuclear Fuel Damage

a. Inspection Scope

On April 13, 2015, as Unit 2 new fuel assemblies were being transferred from the new fuel storage rack to the spent fuel pool in preparations for refueling outage 2R24, a fuel assembly was damaged. One operator initiated raising the new fuel elevator before another operator had moved the assembly clear of the elevator travel path. The fuel assembly was impacted by the top of the new fuel elevator resulting in the fuel assembly being determined unacceptable for use in the core. The inspectors verified the status of safety equipment and barriers, assessed radiological impacts, and observed command and control functions. The inspectors also performed a walkdown to verify that the damaged assembly was stabilized and that spent fuel assemblies were not affected.

b. Findings

No findings were identified.

These activities constitute completion of one event follow-up sample, as defined in Inspection Procedure 71153.

4OA5 Other Activities

Quarterly Performance Assessment In the NRCs annual assessment letter (ML15063A499), dated March 4, 2015, the NRC documented that the performance of Arkansas Nuclear One, Units 1 and 2, was within the Multiple/Repetitive Degraded Cornerstone Column (Column 4) of the NRCs Reactor Oversight Process Action Matrix.

In accordance with NRC Inspection Manual Chapter 0305, Operating Reactor Assessment Program, Issued April 9, 2015, a quarterly review of performance is required for a plant whose performance is in Column 4 of the Action Matrix.

On July 1, 2015, NRC management reviewed inspection and performance indicator results for Units 1 and 2. The NRC determined that continued plant operation was acceptable in the Multiple/Repetitive Degraded Cornerstone of the Reactor Oversight Process Action Matrix. In addition, no additional regulatory actions beyond those described in the annual assessment letter were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On April 29, 2015, the inspectors presented the inservice inspection activities results to Mrs. S. Pyle, Regulatory Assurance Manager and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed none of the information reviewed was proprietary.

On May 12, 2015, the inspectors held a public meeting at the Lakepoint Conference Center in London, Arkansas, to present the results of the 2014 end-of-cycle performance review of Arkansas Nuclear One, Units 1 and 2. The inspectors presented inspection results and enforcement actions from January 1, 2014, through December 31, 2014.

On May 21, 2015, the NRC held a public Commission Meeting to discuss the results of the Agency Action Review Meeting in Rockville, Maryland. The NRC staff and licensee discussed, in part, performance at Arkansas Nuclear One and performance improvement plans with the Commission.

On June 25, 2015, the inspectors presented the radiation safety inspection results to Mr. D. James, Director, Regulatory Affairs, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On July 9, 2015, the inspectors presented the inspection results to Mr. J. Browning and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On July 27, 2016, the NRC discussed the results of the review of contested violation, NCV 05000313, 368/2015002-04, with Ms. S. Pyle, Regulatory Assurance Manager, and other members of the licensee staff. The revised NCV is documented in this report.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. Barborek, Engineer
R. Barnes, Director, Regulatory Affair & Performance Indicators
L. Blocker, Nuclear Oversight Manager
J. Browning, Site Vice President
P. Butler, Design and Program Engineering Manager
B. Daiber, Recovery Manager
B. Davis, Engineering Director
G. Doran, Specialist, Radiation Protection
T. Evans, General Manager of Plant Operations
K. Gaston, Engineer
M. Gibson, Supervisor, ALARA
D. James, Director, Regulatory Affairs & Recovery
D. Marvel, Radiation Protection Manager
N. Mosher, Licensing Specialist
D. Pehrson, Unit 1 Assistant Operations Manager
S. Pyle, Regulatory Assurance Manager
B. Short, Senior Licensing Specialist
M. Smith, Coordinator, ALARA
J. Toben, Security Manager
D. Varvil, Engineer

NRC

D. Alley, Chief, Component Integrity Branch
T. Lupold, Chief, Mechanical and Civil Engineering Branch
S. Cumbridge, Component Integrity Branch
J. Tsao, Component Integrity Branch
K. Hoffman, Component Integrity Branch

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000313/2015002-01 NCV Inadequate Procedure for Severe Weather Preparation
05000368/2015002-01 (Section 1R01.2)
05000368/2015002-02 NCV Failure to Protect Motor Control Center from Potential Pipe Spray (Section 1R06)

Attachment 1

Opened and Closed

05000368/2015002-03 FIN Failure to Verify Material Properties Prior to Installation (Section 1R08.1)
05000313/2015002-04 NCV Failure to Perform Testing of Diesel Fuel Oil Transfer
05000368/2015002-04 Piping (Section 1R08.2)

Closed

05000368/2014003-05 URI Proper ASME Code Classification of RCS Sample System (Section 1R08)
05000368/2014003-06 URI Inservice Testing of the Diesel Fuel Oil Transfer Piping (Section 1R08)
05000368/2014004-00 LER Technical Specification 3.0.4 Violation due to a Mode Change with an Inoperable Emergency Feedwater Pump (Section 4OA3)

LIST OF DOCUMENTS REVIEWED