IR 05000313/2021010
| ML22010A290 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 01/13/2022 |
| From: | Ramirez-Munoz F Division of Reactor Safety IV |
| To: | Sullivan J Entergy Operations |
| References | |
| IR 2021010 | |
| Download: ML22010A290 (14) | |
Text
January 13, 2022
SUBJECT:
ARKANSAS NUCLEAR ONE - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000313/2021010 AND 05000368/2021010
Dear Mr. Sullivan:
On November 18, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Arkansas Nuclear One. On December 1, 2021, the NRC inspectors discussed the results of this inspection with Mr. John Dinelli 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. However, the team did find some work environment challenges in the security department. Through interviews with 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 mostly by inadequate staffing and excessive overtime. This is not a new issue at Arkansas Nuclear One. Our previous problem identification and resolution inspection, performed in 2019 (05000313/2019011 and 05000368/2019011 (ML19276E481)), identified similar concerns. The security staff have experienced some positive improvements in areas such as work environment cleaning, personalized radios, and chair replacement. Similarly, electrical maintenance, instrumentation and controls, and computer support indicated that staffing and overtime were recurring complaints. The team indicated that continued degradation of staff morale, due to fatigue, could negatively impact staff performance and the safety-conscious work environment, and potentially impact plant safety.
No findings or violations of more than minor significance were identified during this inspection.
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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Frances C. Ramirez Munoz, Team Lead Inspection Programs & Assessment Team Division of Reactor Safety Docket Nos. 05000313 and 05000368 License Nos. DPR-51 and NPF-6
Enclosure:
Inspection Report
Inspection Report
Docket Numbers:
05000313 and 05000368 License Numbers:
DPR-51 and NPF-6 Report Numbers:
05000313/2021010 and 05000368/2021010 Enterprise Identifier:
I-2021-010-0002 Licensee:
Entergy Operations, Inc.
Facility:
Arkansas Nuclear One Location:
Russellville, AR Inspection Dates:
November 1 to November 18, 2021 Inspectors:
R. Azua, Senior Reactor Inspector and Team Leader T. DeBey, Resident Inspector L. Flores, Reactor Inspector D. Reinert, Reactor Inspector Approved By:
Frances C. Ramirez Munoz, Team Lead Inspection Programs & Assessment Team 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 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.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IPs could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely while other portions were performed on site. The inspection documented below met the objectives and requirements for completion of the IP.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) 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.
Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a 5-year review of the Arkansas Nuclear One, Unit 1, emergency feedwater and associated emergency feedwater initiation and control systems (EFIC).
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 safety-conscious work environment.
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.
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, that the staff at Arkansas Nuclear One 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.
As part of this inspection, the team selected the Unit 1 emergency feedwater and associated EFIC systems for a focused review within the corrective action program.
For these systems, the team performed sample selections of condition reports, looking at the adequacy of the licensee's evaluation process for determining which items are placed in the corrective actions process, and the corrective actions taken.
The team also reviewed the licensee's use of operational experience and the Part 21 process with respect to these systems. Finally, the team performed walkdowns of accessible portions of these systems.
Based on these walkdowns, the material condition of the emergency feedwater system appeared to be adequate. However, regarding the EFIC system, a review of associated condition reports indicates a system that is experiencing aging issues.
The system cards show signs of temperature susceptibilities, resulting in voltage drift.
Even though the licensee has a vendor that can refurbish these cards, when needed, warehouse stock of these cards was found to be low. As a result, the team identified that low inventory may have been a contributing factor for a number of preventive maintenance activities being deferred. The licensee staff is aware of these issues and indicated that a replacement system is in the works. This effort will not begin until 2025, with completion to occur by 2028. In the meantime, the licensee indicated that they would evaluate the need for increasing warehouse stock of these cards. The licensee also recently purchased replacement cards from another facility and have indicated that they plan to evaluate whether they can dedicate them for use at Arkansas Nuclear One.
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.
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 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. A couple of minor examples of process errors regarding Part 21 reports were identified and entered into the licensee's corrective action program.
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 effective departmental self-assessment and audit process. The audits that the team reviewed were very detailed, thorough, and identified issues.
Assessment 71152B Safety-Conscious Work Environment: The team interviewed approximately twenty individuals in ten one-on-one sessions and two group interview sessions of five individuals each (individuals were masked and socially-distant during these group interviews). The interviewing inspector performed all of these interviews remotely. The purpose of these interviews was
- (1) to evaluate the willingness of your staff to raise nuclear safety issues, either by initiating a condition report or by another method,
- (2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and
- (3) to evaluate your safety-conscious work environment. The focus group participants included personnel from security, electrical maintenance, instrumentation and controls, and computer support. Overall, Arkansas Nuclear One has an adequate safety-conscious work environment.
Willingness to Raise Nuclear Safety Issues: In the interviews, the team found no evidence of challenges to the safety-conscious work environment. Individuals in these groups expressed a willingness to raise nuclear safety concerns and other issues through at least one of the several means available.
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. This degradation in morale appears to be caused mostly by inadequate staffing and excessive overtime. This is not a new issue at Arkansas Nuclear One. Our previous problem identification and resolution inspection identified similar concerns. The security department staff have experienced some positive efforts such as bullet resistant enclosure cleaning, personalized radios, and chair replacement.
Regarding electrical maintenance, I&C, and computer support personnel, staffing and overtime were a recurring complaint. Staff indicated they had good equipment, but not enough to go around. They indicated that resources shared during outages could be better managed so that the staff is not shorthanded at the end of the outage.
The team posited that continued degradation of staff morale due to fatigue, could negatively impact staff performance. Specifically, tired, distracted people make mistakes. Low morale may ultimately have a negative impact on the safety-conscious work environment.
Overall, the team concluded that all work groups at Arkansas Nuclear One maintained a healthy safety-conscious work environment. However, morale issues may have a deleterious effect on staff performance and potentially on plant safety.
Employee Concerns Program: The team looked at Arkansas Nuclear Ones Employee Concerns Program (ECP). The team interviewed the ECP manager and reviewed a number of investigations. Overall, the team determined that the investigation packages were of excellent quality, clearly demonstrating steps taken and basis for conclusions. In addition, the ECP manager demonstrated detailed knowledge of all the cases that were reviewed.
Minor Violation 71152B Minor Violation: Failure to Follow Procedure for Concurrent Verification Screening: Licensee personnel failed to follow procedural requirements for performing concurrent verification as specified in Step 8.7.5.5. of Procedure OP-1304.041, Unit 1 Reactor Protection System Channel A Calibration. The inspectors determined the performance deficiency was minor.
The licensees procedure for concurrent verification Procedure EN-HU-102, Procedure and Work Instruction Use and Adherence, states that the verifier will: OBSERVE performer before and during execution, to confirm performer takes correct action on correct component. Contrary to this, technicians failed to follow the procedure. Specifically, the physical constraints of the location of the terminal board prevented the verifier from observing the performers action during the execution of the step, so the technicians failed to perform the concurrent verification as specified in Procedure OP-1304.041, Step 8.7.5.5, resulting in an incorrect wire being lifted from a terminal board in channel A. This action caused the loop A reactor coolant system low signal to be lost and three unexpected annunciator actuations occurred in the control room: SASS Mismatch, A OTSG BTU limit, and RCS Flow Lo. Prior to the calibration activity, reactor protection system channel A had been placed in bypass for the planned I&C work and there were no valid plant trip signals generated and no plant transients occurred.
Through the review of this issue, the team identified a concern that was transmitted to licensee management. Specifically, technicians interviewed indicated that there were a number of procedures that required concurrent verification, where it may not be physically possible or where COVID restrictions would prevent concurrent verification. For these instances, licensee staff resorted to placing tape or plastic clips on the leads to be removed as unique visual identifiers. Through other conversations, it appeared that these compensatory measures had been tacitly accepted and informally approved by the staff's supervision, as a form of work-around, however, they had not been documented or formally approved. Further, some identified training efforts did not clearly explain that concurrent verification required the verifier to fully observe the whole evolution of landing leads. Finally, Procedure EN-HU-102, Step 11.3, When to Apply, states in part that concurrent verification is to be used for actions that have a high potential to lead to irreversible consequences, such as fuel damage, loss of safety function, or loss of reactivity control. The use of concurrent verification for this step of the reactor protection system calibration was inconsistent with the intended use of this administrative tool. The team was concerned that the misuse and overuse of this critical administrative tool, coupled with the normalization of work-arounds, has diminished the positive effect of this tool, and could result in more serious events, if left uncorrected. The licensee entered the minor violation, and this specific concern, in their corrective action program (CR-1-21-3159 and CR-1-21-3160).
Enforcement:
This failure to comply with procedural requirements did not affect the mitigating systems cornerstone objective. As a result, this issue is of low safety significance and constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On December 1, 2021, the inspectors presented the biennial problem identification and resolution inspection results to Mr. John Dinelli and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
CALC-80-D-
1083C-01
EFIC System Loop Error and Setpoint Analysis
Corrective Action
Documents
CR-ANO-HQN-
XXXX-XXXXX
20-01572
Corrective Action
Documents
CR-ANO-X-
XXXX-XXXXX
1-2012-00387, 1-2016-05281, 1-2017-00143, 1-2017-01565,
1-2017-02018, 1-2017-02543, 1-2018-01514, 1-2018-02595,
1-2018-03236, 2-2018-00852, C-2018-03684, 1-2019-00292,
1-2019-00797, 1-2019-02219, 1-2019-02250, 1-2019-02476,
1-2019-02493, 1-2019-02522, 1-2019-02553, 1-2019-02670,
1-2019-02820, 1-2019-02833, 1-2019-02963, 1-2019-02993,
1-2019-03440, 1-2019-03578, 1-2019-03716, 1-2019-04156,
1-2019-04660, 1-2019-04676, 2-2019-02163, 2-2019-02164,
2-2019-02396, 2-2019-02477, 2-2019-02607, C-2019-00070,
C-2019-00271, C-2019-02561, C-2019-03186, C-2019-03880,
C-2019-03949, C-2019-03958, C-2019-03992, C-2019-04182,
C-2019-04254, C-2019-04684, C-2019-04711, C-2019-04770,
C-2019-04842, 1-2020-00006, 1-2020-00015, 1-2020-00031,
1-2020-00085, 1-2020-00102, 1-2020-00118, 1-2020-00153,
1-2020-00160, 1-2020-00197, 1-2020-00218, 1-2020-00259,
1-2020-00316, 1-2020-00354, 1-2020-00445, 1-2020-00462,
1-2020-00558, 1-2020-00598, 1-2020-00668, 1-2020-00681,
1-2020-00776, 1-2020-00796, 1-2020-00840, 1-2020-00894,
1-2020-00952, 1-2020-01021, 1-2020-01124, 1-2020-01263,
1-2020-01268, 1-2020-01317, 1-2020-01479, 1-2020-01531,
1-2020-01663, 1-2020-01667, 1-2020-01681, 1-2020-01745,
1-2020-02463, 2-2020-00039, 2-2020-00100, 2-2020-00101,
2-2020-00117, 2-2020-00213, 2-2020-00232, 2-2020-00354,
2-2020-00560, 2-2020-00629, 2-2020-00658, 2-2020-00678,
2-2020-00751, 2-2020-00867, 2-2020-00872, 2-2020-01076,
2-2020-01305, 2-2020-01589, 2-2020-01630, 2-2020-01642,
2-2020-01688, 2-2020-01700, 2-2020-01770, 2-2020-02079,
2-2020-02248, 2-2020-02469, 2-2020-02473, 2-2020-02474,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2-2020-02585, 2-2020-02643, 2-2020-02797, 2-2020-02904,
2-2020-02921, 2-2020-02924, 2-2020-02964, 2-2020-02971,
2-2020-03036, 2-2020-03061, 2-2020-03815, 2-2020-03843,
2-2020-03913, C-2020-00259, C-2020-01523, C-2020-01762,
C-2020-02818, C-2020-03099, 1-2021-00263, 1-2021-00300,
1-2021-00308, 1-2021-00319, 1-2021-00347, 1-2021-00378,
1-2021-00391, 1-2021-00457, 1-2021-01780, 1-2021-01986,
1-2021-02094, 1-2021-02377, 1-2021-02523, 1-2021-02573,
1-2021-02611, 1-2021-02634, 1-2021-02717, 1-2021-02718,
1-2021-02735, 1-2021-02978, 1-2021-03021, 1-2021-03075,
2-2021-00048, 2-2021-00060, 2-2021-00390, 2-2021-00952,
2-2021-01120, 2-2021-01189, 2-2021-01544, 2-2021-02416,
2-2021-02721, 2-2021-03343, C-2021-01274, C-2021-01649,
C-2021-01749, C-2021-01942
Corrective Action
Documents
LO-ALO-XXXX-
XXXXX
20-00038
Corrective Action
Documents
OE-NOE-XXXX-
XXXXX
20-00150, 2021-00019, 2021- 00020, 2021-00089,
21-00093, 2021-00104
Corrective Action
Documents
Resulting from
Inspection
1/2/C/HQN-XXX-
XXXXX
1-2021-03075, 1-2021-03159, 1-2021-03160, C-2021-03034,
HQN-2021-01881, HQN-2021-01899
Engineering
Changes
Improve Air Flow Inside Panels 2C36 and 2C37
Arkansas Nuclear One - Unit 2, Technical Specifications
Amendment
25
Arkansas Nuclear One - Unit 2, Safety Analysis Report
Amendment
ASME OM-2012
Operation and Maintenance of Nuclear Power Plants
04/08/2013
LO-ALO-2019-
00082
Pre-NRC Inspection Self-Assessment, Radiological Hazard &
Exposure Controls and Occupational ALARA Planning and
Controls
11/21/2019
Miscellaneous
LO-ALO-2020-
00048
Self-Assessment Radiation Safety - Hazard Assessment,
Airborne Controls and Performance Indicators Plant: ANO
2/09/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NQ-2019-028
QA Audit Report QA-14/15-2019-ANO-1, 2019 QA Audit of
Radiation Protection/Radwaste at Arkansas Nuclear One
(ANO)
10/24/2019
NQ-2020-021
QA-11-2020-ANO-1 Materials Purchasing and Contracts Audit
Notification/Audit Plan Memorandum
05/07/2020
NQ-2021-006
21 QA Audit of Engineering Programs and Arkansas
Nuclear One
04/08/2021
NQ-2021-012
QA Audit of Combined Operation and Technical
Specifications Program at Arkansas Nuclear One
07/15/2021
Guidelines for Inservice Testing at Nuclear Power Plants
PEAR-95-0290
Replacement Valve for 2CV-1456-2
11/03/1995
PO-955564
Purchase Order
11/06/1995
SEP-ANO-2-IST-
1(2)(3)
ANO Unit 2 Inservice Testing Bases Document
SIPD-9803
Addition of Reflash Capability to K16-C5 Electrical Equipment
Room Temperature Hi
11/04/2021
ULD-1-SYS-12
Upper Level Document ANO Unit 1 Emergency Feedwater
System
1104.027
Battery and Switchgear Emergency Cooling System
1304.205
Unit 1 EFIC Channel A Monthly Test, SG Pressure Greater
than 750 PSIG
1304.207
Unit 1 EFIC Channel C Monthly Test, SG Pressure Greater
than 750 PSIG
2305.017
Procurement Engineering Process
Employee Concerns Program
EN-FAP-MP-011
Identification & Processing of Potential Candidates for
Commercial Grade Dedication and Alternate Sourcing
Human Performance Traps & Tools
Procedure and Work Instruction Use and Adherence
Corrective Action Program
45, 46
Causal Analysis Process
Planning
Procedures
Maintenance Standard for Torque Application
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Maintenance Configuration Control
Operating Experience Program
On-site Safety Review Committee
Safety Conscious Work Environment (SCWE) Policy
Nuclear Safety Culture Monitoring
Radiation Worker Expectations
Access Control for Radiologically Controlled Areas
Work Request Generation, Screening and Classification
OP-1000.120
ANO Fire Impairment Program
OP-2104.029
Service Water Operations
117
WO 183059, 448859, 501163, 512454, 512455, 512457, 528417,
541573, 544453
Work Orders
Work Standard
T-23467