IR 05000313/2019011

Biennial Problem Identification and Resolution Inspection Report 05000313/2019011 and 05000368/2019011

ML19276E481
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/02/2019
From:	Geoffrey Miller Division of Reactor Safety IV
To:	Richard Anderson Entergy Operations
Azua R
References
IR 2019011
Download: ML19276E481 (12)

Text

October 2, 2019

SUBJECT:

ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 - BIENNIAL

PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION

REPORT 05000313/2019011 AND 05000368/2019011

Dear Mr. Anderson:

On August 22, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed a biennial problem identification and resolution inspection at your Arkansas Nuclear One Units 1 and 2, and discussed the results of this inspection with Mr. Brian Patrick and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

The NRC inspectors did not identify any finding or violation of more than minor significance. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Geoffrey B. Miller, Deputy Director Division of Reactor Safety

Docket Nos. 05000313 and 05000368 License Nos. DPR-51 and NPF-6

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000313 and 05000368

License Numbers:

DPR-51 and NPF-6

Report Numbers:

05000313/2019011 and 05000368/2019011

Licensee:

Entergy Operations, Inc.

Facility:

Arkansas Nuclear One, Units 1 and 2

Location:

Russellville, Arkansas

Inspection Dates:

August 5, 2019, to August 22, 2019

Inspectors:

I. Anchondo-Lopez, Reactor Inspector

R. Azua, IPAT, Acting Team Leader

P. Jayroe, Reactor Inspector

T. Sullivan, Resident Inspector

Approved By:

Geoffrey B. Miller

Deputy Director

Division of Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Arkansas Nuclear One, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs)in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.

Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)

The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety-conscious work environment (SCWE).

• Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems.

• Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.

• Safety-Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a SCWE.

INSPECTION RESULTS

Assessment 71152B Effectiveness of Problem Identification: Based on the samples reviewed, the team determined that the licensee's performance in this area adequately supported nuclear safety. Overall, the team found that the licensee was identifying and documenting problems at an appropriately low threshold that supported nuclear safety. On average, the licensee was identifying and documenting approximately 1360 Condition Reports (CRs) per month.

Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the licensee was appropriately prioritizing and evaluating issues to support nuclear safety. Of the samples reviewed, the team found that the licensee correctly characterized each condition report as to whether it represented a condition adverse to quality, and then prioritized the evaluation and corrective actions in accordance with program guidance.

Effectiveness of Corrective Actions: Overall, the team concluded that the licensee's corrective actions supported nuclear safety. Specifically, Arkansas Nuclear One, Units 1 and 2, developed effective corrective actions for the problems evaluated in the corrective action program and generally implemented these corrective actions in a timely manner commensurate with their safety significance. However, the team did identify some CRs that were difficult to follow or where it was not clear that the corrective actions were addressed. Ultimately, it was determined that the corrective actions were all completed appropriately, but that the documentation could have been better. It was noted by the team that these examples were for CRs written in 2016 and 2017. More recent CRs appeared to be better written with a clear line of sight as to how the corrective actions were addressed.

Corrective Action Program Assessment: Based on the samples reviewed, the team determined the licensee's corrective action program complied with regulatory requirements and self-imposed standards, and the licensee's implementation of the corrective action program adequately supported nuclear safety. The team found that management's oversight of the corrective action program process was effective.

Observation: Operating Experience, Self-Assessments, and Audit Assessment 71152B Operating Experience: The team reviewed a variety of sources of operating experience including Part 21 notifications and other vendor correspondence, NRC generic communications, and publications from various industry groups including Institute of Nuclear Power Operations (INPO) and Electric Power Research Institute (EPRI). The team determined that Arkansas Nuclear One, Units 1 and 2, is adequately screening and addressing issues identified through operational experience that apply to the station and that this information is evaluated in a timely manner once it is received.

Self-Assessments and Audit Assessment: The team reviewed a sample of the licensee's departmental self-assessments and audits to assess whether they regularly identified performance trends and effectively addressed them. The team also reviewed audit reports to assess the effectiveness of assessments in specific areas. Overall, the team concluded that the licensee had an adequate departmental self-assessment and audit process.

Observation: Safety-Conscious Work Environment Assessment (SCWE)71152B Safety-Conscious Work Environment: The team interviewed approximately forty individuals in eight group interviews. The purpose of these interviews was

(1) to evaluate the willingness of your staff to raise nuclear safety issues, either by initiating a CR or by another method;

(2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems; and

(3) to evaluate your SCWE. The focus group participants included personnel from Security, Radiation Protection, Projects, and Instrumentation and Controls. Overall, Arkansas Nuclear One, Units 1 and 2, has an adequate SCWE.

Willingness to Raise Nuclear Safety Issues: In most focus groups, the team found no evidence of challenges to the SCWE. Individuals in these groups expressed a willingness to raise nuclear safety concerns and other issues through at least one of the several means available. However, the team found some work environment challenges in the Security Department. Through interviews with the staff members, the team identified a significant decline in morale that appears to permeate throughout the Security Department work environment. This degradation in morale appears to be caused by excessive overtime. The team brought this observation to senior plant managements attention, who were aware of many of the issues. While not currently affecting the SCWE, the team discussed with station management that continued degradation of staff morale could negatively impact staff performance. Specifically, distracted people are more likely to make mistakes.

Overall, the team concluded that all work groups at Arkansas Nuclear One, Units 1 and 2, maintained a healthy SCWE. However, morale issues in the Security Department may have a negative effect on staff performance and potentially on plant safety.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On August 22, 2019, the inspectors presented the biennial problem identification and resolution inspection results to Mr. B. Patrick and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71152B

Corrective

Action

Documents

CR-ANO-X-

XXXX-XXXXX

1-2015-00631, 1-2015-01110, 1-2016-00673, 1-2016-03526,

1-2016-04473, 1-2016-04833, 1-2017-02109, 1-2017-02512,

1-2017-02518, 1-2017-03143, 1-2017-03472, 1-2017-03537,

1-2017-03673, 1-2018-00052, 1-2018-00053, 1-2018-00180,

1-2018-00181, 1-2018-00182, 1-2018-00530, 1-2018-00733,

1-2018-00851, 1-2018-00977, 1-2018-00999, 1-2018-01260,

1-2018-01348, 1-2018-01351, 1-2018-01408, 1-2018-01495,

1-2018-01610, 1-2018-01792, 1-2018-01959, 1-2018-02240,

1-2018-02282, 1-2018-02561, 1-2018-02821, 1-2018-02824,

1-2018-02845, 1-2018-03238, 1-2018-03540, 1-2018-03567,

1-2018-03614, 1-2018-03632, 1-2018-03729, 1-2018-03754,

1-2018-03930, 1-2018-04294, 1-2018-04314, 1-2018-04376,

1-2018-05007, 1-2018-05186, 1-2018-05187, 1-2018-05188,

1-2018-05206, 1-2018-05206, 1-2018-05244, 1-2018-05244(1),

1-2018-05311, 1-2018-05360, 1-2019-00141, 1-2019-00219,

1-2019-00290, 1-2019-00795, 1-2019-01017, 1-2019-01073,

1-2019-01073(1), 1-2019-01222, 1-2019-01224, 2-2002-02040,

2-2006-00318, 2-2008-01439, 2-2008-01763, 2-2010-00036,

2-2010-02793, 2-2010-02863, 2-2010-02865, 2-2012-02609,

2-2014-03154, 2-2015-00793, 2-2016-00789, 2-2016-00946,

2-2016-01071, 2-2016-04263, 2-2016-04277, 2-2017-03161,

2-2017-03337, 2-2017-05291, 2-2017-05330, 2-2017-05335,

2-2017-05335(1), 2-2017-05335(2), 2-2017-05335(3),

2-2017-06020, 2-2017-06114, 2-2018-00425, 2-2018-00867,

2-2018-00868, 2-2018-01418, 2-2018-02045, 2-2018-02545,

2-2018-03171, 2-2018-03412, 2-2018-03431, 2-2018-03442,

2-2018-03454, 2-2018-03454(1), 2-2018-03601, 2-2018-03750,

2-2018-04556, 2-2019-00430, 2-2019-00432, 2-2019-00780,

2-2019-00856, 2-2019-00863, 2-2019-00935, 2-2019-00936,

2-2019-00937, 2-2019-00938, 2-2019-00948, 2-2019-00949,

2-2019-00951, 2-2019-00952, 2-2019-00953, 2-2019-00954,

2-2019-00955, 2-2019-00956, 2-2019-00957, 2-2019-00958,

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

2-2019-00959, 2-2019-01073, 2-2019-01263, C-2012-01591,

C-2015-03033, C-2016-00614, C-2017-00203, C-2017-03180,

C-2017-04123, C-2017-04125, C-2017-04482, C-2017-04495,

C-2017-04517, C-2017-04759, C-2018-00299, C-2018-00495,

C-2018-00717, C-2018-01121, C-2018-01465, C-2018-01484,

C-2018-01846, C-2018-01846(1), C-2018-01928,

C-2018-02045, C-2018-02053, C-2018-02902, C-2018-03034,

C-2018-03052, C-2018-03070(1), C-2018-03210,

C-2018-03443, C-2018-03597, C-2018-03735, C-2018-04246,

C-2018-04316, C-2018-04349, C-2018-04570, C-2018-04572,

C-2019-00535(1), C-2019-01406, C-2019-02144,

C-2019-02193, C-2019-02894

Drawings

2HBC-68-1

Large Pipe Isometric Service Water Piping from Loop 1 Header

to Penetration Valve 2CV-1511-1

2HCC-313-1

Large Pipe Isometric Service Water Piping from 2VE-IB to

Service Water Header #2

2HCC-314-1

Large Pipe Isometric Service Water from Control Room

Emergency Chiller 2VE-1B to 2K-4B Heat Exchanger

CBV-A%-10-

0011

Check Valve Sch 40 Socket Weld Ends, ANSI Class 600

M-2210

Piping & Instrumentation Diagram Service Water System,

Unit 2

M-507

Instrument Line Class Specification

ULD-2-SYS-10

ANO Unit 2 Service Water System

Miscellaneous

6030.109

Installation of Electrical Cable & Wire

Procedures

1000.006

Procedure Control

1104.023

Diesel Oil Transfer Procedure

1601.505

Processing of Spent Radioactive Resin

1903.069

Equipment Important to Emergency Response

2104.029

Service Water System Operations

115

CEP-NDE-0965

Visual Welding Inspections ASME, ANSI B31.1

CEP-WP-003

Qualification and Control of Welders

CEP-WP-GWS-1

General Welding Standard ASME/ANSI

COPD-024

Risk Assessment Guidelines

EN-EC-100

Employee Concerns Program

10/11

EN-FAP-LI-001

Performance Improvement Review Group (PRG) Process

EN-LI-102

Corrective Action Program

EN-LI-104

Self-Assessment and Benchmark Process

13/14

EN-LI-118

Cause Evaluation Process

27/29

EN-LI-121

Trending and Performance Review Process

23/25

EN-OE-100

Operating Experience Program

28/32

EN-OP-104

Operability Determination Process

EN-OP-115

Conduct of Operations

EN-PL-100

Nuclear Excellence Model

EN-PL-187

Safety-Conscious Work Environment (SCWE) Policy

EN-PL-190

Maintaining a Strong Safety Culture

EN-QV-109

Audit Process

EN-TQ-114

Licensed Operator Requalification Training Program

EN-WM-102

Work Implementation and Closeout

OP-1032.036

Service Water Piping Leak Evaluation and Monitoring

OP-1102.015

Filling and Draining the Fuel Transfer Canal

OP-1104.002

Makeup and Purification System Operation

OP-1106.016

Condensate, Feedwater, and Steam System Operations

OP-1203-025

Natural Emergencies

OP-1402.240

Inspection of Watertight Hatches

OP-1903.010

EAL Classification

56/57

OP-1903.069

Equipment Important to Safety

OP-2104.036

Emergency Diesel Generator Operations

Self-

Assessments

LO-ALO-2018-

00063

Self-Assessment - Radiation Safety Hazard Assessment,

Airborne Controls, and Performance Indicators

08/05/2019

QA-10-2018-

ANO-1

2018 QA Audit of Maintenance

07/13/2018

QA-14/15-2017-

ANO-01

2017 QA Audit of Combined Radiation Protection and

Radwaste

11/14/2017

QA-3-2019-ANO-

2019 QA Audit of Corrective Action Program at Arkansas

Nuclear One

06/19/2019

QA-8-2019-ANO-

2019 QA Audit of Engineering Programs

04/11/2019

Work Orders

WO-XXXXXX

150817, 260381, 261219, 379285, 379287, 457963, 462301,

461547-1, 503751, 506252, 521657-01, 521759

WR-XXXXXX

21140, 421141