IR 05000313/2022003
| ML22312A527 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/09/2022 |
| From: | John Dixon NRC/RGN-IV/DORS/PBD |
| To: | Sullivan J |
| References | |
| EA-22-054, EA-22-070 IR 2022003 | |
| Download: ML22312A527 (43) | |
Text
November 09, 2022
SUBJECT:
ARKANSAS NUCLEAR ONE - INTEGRATED INSPECTION REPORT 05000313/2022003 AND 05000368/2022003 AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Joseph Sullivan:
On September 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Arkansas Nuclear One. On October 6, 2022, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. Both of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with section 2.3.2 of the Enforcement Policy.
A violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 37 with respect to large components containing category 2 quantities of radioactive material stored in robust structures was identified. However, Entergy Operations, Inc. met all the criteria in NRC Enforcement Guidance Memorandum 14-001, Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52 for the use of enforcement discretion. Therefore, the NRC is exercising enforcement discretion (EA-22-070) and will not issue enforcement action for this violation. Additional details are contained in the enclosure.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Arkansas Nuclear One.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Arkansas Nuclear One.
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, John L. Dixon, Jr., Chief Projects Branch D Division of Operating Reactor Safety Docket Nos. 05000313, 05000368 License Nos. DPR-51, NPF-6
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000313 and 05000368
License Numbers:
Report Numbers:
05000313/2022003 and 05000368/2022003
Enterprise Identifier:
I-2022-003-0005
Licensee:
Entergy Operations, Inc.
Facility:
Arkansas Nuclear One
Location:
Russellville, AR
Inspection Dates:
July 1 to September 30, 2022
Inspectors:
D. Antonangeli, Health Physicist
N. Brown, Resident Inspector
R. Bywater, Senior Resident Inspector
D. Childs, Resident Inspector
K. Clayton, Senior Operations Engineer
T. DeBey, Resident Inspector
R. Deese, Senior Reactor Analyst
S. Hedger, Senior Emergency Preparedness Inspector
N. Hernandez, Operations Engineer
R. Kopriva, Senior Reactor Inspector
J. O'Donnell, Senior Health Physicist
A. Patz, Senior Resident Inspector
A. Smallwood, Resident Inspector
H. Strittmatter, Emergency Preparedness Inspector
F. Thomas, Reactor Inspector
Approved By:
John L. Dixon, Jr., Chief
Projects Branch D
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated 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
Failure to Critique a Weakness During a Biennial Exercise Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000313,05000368/2022003-01 Open/Closed
[H.12] - Avoid Complacency 71114.01 The inspectors identified a Green, non-cited violation of 10 CFR 50.47(b)(14) for the licensees failure to identify and correct weaknesses in emergency response organization performance during a biennial emergency preparedness exercise conducted on August 9, 2022. Specifically, the licensee did not identify an example of performance that would have precluded effective implementation of the emergency plan if it occurred during an actual radiological emergency (untimely notification).
Failure to Implement Three Mile Island Action Item Requirements for Pressurizer Heaters Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000313/2022003-02 Open/Closed None (NPP)71152A The inspectors identified two examples of a Green, non-cited violation of the Confirmatory Order issued to Arkansas Nuclear One, Unit 1, dated January 2, 1980, for the licensees failure to implement requirements set forth in NUREG-0578, TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations. First, as-measured pressurizer ambient heat losses exceeded the predetermined pressurizer heater capacity needed to establish and maintain natural circulation at hot standby conditions when offsite power was not available. The licensee determined this was acceptable based on their conclusion that hours was an acceptable time duration for the pressurizer heaters requirement. Second, in the event of a loss of offsite power with failure of B-train emergency power, manual operator actions outside the main control room are required to restore power to the minimum-required pressurizer heater capacity powered by A-train emergency power.
Additional Tracking Items
Type Issue Number Title Report Section Status EDG EA-22-070 Enforcement Action EA-22-070: Failure to Comply with Title 10 CFR 37 Requirements for Radioactive Waste 71124.08 Closed LER 05000368/2021-002-00 Material Defect in Primary Coolant System that Cannot be Found Acceptable Under American Society of Mechanical EngineersSection XI 71153 Closed
PLANT STATUS
Unit 1 began the inspection period at full power and began an end-of-operating cycle power coast down on August 26, 2022. Unit 1 was operating at approximately 73 percent power at the end of the inspection period.
Unit 2 operated at or near full power for the entire inspection period.
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 performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
External Flooding Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on July 25, 2022.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1 and Unit 2, alternate ac diesel generator, during a planned Unit 2 emergency diesel generator B outage, on August 18, 2022
- (2) Unit 1 and Unit 2, common feedwater train B, during maintenance on Unit 1 common feedwater injection valve CV-2660A, on September 12, 2022
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 1, vital dc power system train D-03 and train D-04, on September 9, 2022.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Unit 1, intake structure, fire zone FZ-1061, on July 20, 2022
- (2) Unit 1, cable spreading room, fire zone FZ-1043, on August 24, 2022
- (3) Unit 2, cable spreading room, fire zone FZ-2098-L, on August 30, 2022
- (4) Unit 1 and Unit 2, technical support center ventilation equipment room, fire zone FZ-3015, on September 6, 2022
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) Unit 1, intermediate cooling water heat exchanger B, on August 8, 2022
71111.07SIX - Heat Exchanger/Sink Performance Ultimate Heat Sink Containment Device and Dam (IP Section 03.05)
The inspectors evaluated the ultimate heat sink performance containment device and dam on the following:
(1)ultimate heat sink containment device and dam (emergency cooling pond)
71111.07T - Heat Exchanger/Sink Performance Heat Exchanger (Service Water Cooled) (IP Section 03.02)
The inspectors evaluated heat exchanger performance on the following:
- (1) Unit 2 emergency feedwater pump room cooler 2VUC-6A, cooled by service water
Heat Exchanger (Closed Loop) (IP Section 03.03) (2 Samples)
The inspectors evaluated heat exchanger performance on the following:
(1)alternate ac generator - after cooler 2E-132, closed loop, air cooled (2)alternate ac generator - lube oil cooler 2E-130, closed loop, air cooled
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (2 Samples)
- (1) The inspectors reviewed and evaluated the Unit 2 licensed operator examination failure rates for the requalification annual operating exam administered for June 6 - July 22, 2022.
- (2) The inspectors reviewed and evaluated the Unit 1 licensed operator examination failure rates for the requalification annual operating exams administered June 13 - July 22, 2022.
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
- (1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered June 6 - July 22, 2022.
Annual Requalification Operating Tests The inspectors evaluated the adequacy of the licensees annual requalification operating test.
Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.
Requalification Examination Security The inspectors evaluated the ability of the licensee to safeguard examination material, such that the examination is not compromised.
Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.
Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.
Control Room Simulator The inspectors evaluated the adequacy of the licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.
Problem Identification and Resolution The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)
- (1) The inspectors observed and evaluated licensed operator performance in the Unit 1 control room during A and C reactor protection system control rod drive breaker trip testing on August 3, 2022.
- (2) The inspectors observed and evaluated licensed operator performance in the Unit 1 control room during high-risk operation for reactor coolant system T-average reduction at end of the fuel cycle on August 22, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)
- (1) The inspectors observed and evaluated Unit 1 simulator scenarios for the biennial requalification exam for crew E on July 6, 2022.
- (2) The inspectors observed and evaluated Unit 2 simulator requalification training on a reactor trip with a stuck control rod and a plant fire on August 25, 2022.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) The inspectors reviewed the site 10 CFR 50.65(a)(3) periodic assessment for the period of July 1, 2020, to December 31, 2021, on July 18, 2022
- (2) Unit 2, vital ac inverter 2Y-2224 transfer switch replacement, on September 22, 2022
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
- (1) Unit 1, 480 V motor control center B61, on September 29, 2022
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 2, elevated risk due to safety injection tank A, C, and D pressure adjustments, on July 20, 2022
- (2) Unit 2, elevated risk due to removing emergency diesel generator B from service for a planned outage, on August 18, 2022
- (3) Unit 2, elevated risk during troubleshooting and repair of a power supply voltage anomaly on control element assembly 45, on August 23, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 1 and Unit 2, alternate ac diesel generator functionality assessment due to load reduction following high lubricating oil temperature alarm, on August 12, 2022
- (2) Unit 1, reactor building sump suction valve CV-1414 operability assessment due to loss of closed indication during stroke testing on August 16, 2022
- (3) Unit 1, sluice gate SG-1 operability assessment coincident with de-energized sluice gate SG-6, on August 18, 2022
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
- (1) Unit 1, low-pressure injection pump A, following preventive maintenance activities, on August 1, 2022
- (2) Unit 2, emergency diesel generator B, following preventive maintenance activities, on August 25, 2022
- (3) Unit 1, service water pump C, following preventive maintenance activities, on August 29, 2022
- (4) Unit 2, high-pressure injection pump 2P-89A, following preventive maintenance activities, on September 8, 2022
- (5) Unit 2, vital ac inverter 2Y-2224, after transfer switch replacement, on September 28, 2022
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Partial)
(1)
(Partial)
The inspectors evaluated Unit 1 refueling outage 1R30 activities from September 26 to September 30, 2022. The inspectors completed inspection procedure section 03.01.a.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (5 Samples)
- (1) Unit 1, emergency diesel generator A monthly test, on July 14, 2022
- (2) Unit 1, emergency feedwater initiation and control channel A monthly test, on August 2, 2022
- (3) Unit 1, reactor protection system channel C control rod drive breaker trip test, on August 3, 2022
- (4) Unit 2, safety injection tank 2T-2C and 2T-2D valve stroke and position test, on September 14, 2022
- (5) Unit 2, plant protection system channel C 18-month calibration check, on September 14, 2022
71114.01 - Exercise Evaluation
Inspection Review (IP Section 02.01-02.11) (1 Sample)
- (1) The inspectors evaluated the biennial emergency plan exercise conducted on August 9, 2022. The exercise scenario included heavy rain and thunderstorm conditions necessitating a Unit 1 reduction in power, a misalignment in control rods, rising reactor coolant system activity, a loss of both main feedwater pumps, an electromagnetic relief valve failing open, and a hydrogen sampler tubing leak bypassing containment. This led to a monitored release to the environment.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated the change to procedure 1903.010, "Emergency Action Level Classification," revision 60 (effective May 2022). This involved review of a selection of additional licensee screening and evaluation documentation. These evaluations and reviews do not constitute NRC approval.
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (2 Samples)
The inspectors evaluated:
- (1) The Yellow emergency response organization team emergency preparedness site integrated drill on July 12, 2022.
- (2) The Red emergency response organization team emergency preparedness site integrated drill on September 13, 2022.
71114.08 - Exercise Evaluation - Scenario Review
Inspection Review (IP Section 02.01 - 02.04) (1 Sample)
- (1) The inspectors reviewed the licensee's preliminary exercise scenario that was submitted to the NRC on June 7, 2022, (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML22160A376 and ML22160A378)for the exercise scheduled to occur on August 9, 2022. The inspectors discussed the preliminary scenario with Josh Toben, Manager, Emergency Preparedness, and other members of the emergency preparedness staff on July 6, 2022. The inspectors' review does not constitute NRC approval of the scenario.
RADIATION SAFETY
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (10 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
(1)chemistry count room gamma spectroscopy systems and liquid scintillation counters (2)portable ion chambers and tele-poles stored and ready for use at the radiologically controlled area exit (CA-1)
(3)train bay frisker and continuous air monitor
- (4) Unit 1 and Unit 2, auxiliary building area radiation monitors
- (5) Unit 1 auxiliary building process radiation monitors
- (6) Unit 1 auxiliary building containment purge effluent monitor
- (7) Unit 1 liquid radwaste discharge monitor
- (8) Unit 1, portal monitors, personnel contamination monitors, and small article monitors at CA-1
- (9) Unit 1 iSolo wipe sample counter at CA-1
- (10) Unit 2 main steam line N-16 monitors
Calibration and Testing Program (IP Section 03.02) (15 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) AMP-100, CHP-DR-040
- (2) Canberra ARGOS, ARGOS-002
- (3) Canberra ARGOS, ARGOS-005
- (4) Canberra GEM-5, GEM-002
- (5) Canberra Fast Scan 1
- (6) Eberline AMS-4, AMS-032
- (7) Eberline GSAM, GSAM-007
- (8) Ludlum LM-12 (NRD), CHP-N-021
- (9) Ludlum LM-177, SN 8890
- (10) MGPI WR Telepole, CHP-TEL043
- (11) Mirion iSolo, CHP-C-033
- (12) RADeCO H809-V1, HP-AS-133
- (13) Unit 1 service water loop 2 process radiation monitor RE-3815
- (14) Unit 1 area radiation monitor RE-8008
- (15) Unit 2 containment building high range radiation monitor 2RE-8925 Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (3 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
- (1) Unit 1 liquid radioactive waste monitor RE-4642
- (2) Unit 1 radwaste area vent monitor (SPING 2) RX-9825
- (3) Unit 2 penetration room exhaust (SPING 8) 2RX-9835
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Radioactive Material Storage (IP Section 03.01)
The inspectors evaluated the licensees performance in controlling, labeling, and securing the following radioactive materials:
(1)new low level rad waste storage building (2)old low level rad waste storage building (3)independent spent fuel storage installation pad
Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)
The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:
- (1) Unit 1 filter removal/replacement system
- (2) Unit 2 spent resin transfer system
Waste Characterization and Classification (IP Section 03.03) (2 Samples)
The inspectors evaluated the following characterization and classification of radioactive waste: (1)2021 Part 61 analysis for Tri-Nuke filters (2)2021 Part 61 analysis for dry active waste
Shipping Records (IP Section 03.05) (4 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through a record review:
- (1) RSR 20-061, Type A, Class LSA - II, dry active waste
- (2) RSR 20-084, Type A, Class LSA - II, diversified resin
- (3) RSR 20-093, Type A, Class LSA - III, primary resin
- (4) RSR 21-109, Type A, Class LSA - II, dry active waste
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
- (1) Unit 1 (April 1, 2021, through March 31, 2022)
- (2) Unit 2 (April 1, 2021, through March 31, 2022)
MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)
- (1) Unit 1 (July 1, 2021, through June 30, 2022)
- (2) Unit 2 (July 1, 2021, through June 30, 2022)
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
- (1) Unit 1 (July 1, 2021, through June 30, 2022)
- (2) Unit 2 (July 1, 2021, through June 30, 2022)
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
- (1) Unit 1 (July 1, 2021, through June 30, 2022)
- (2) Unit 2 (July 1, 2021, through June 30, 2022)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)
- (1) Unit 1 (April 1, 2021, through March 31, 2022)
- (2) Unit 2 (April 1, 2021, through March 31, 2022)
BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)
- (1) Unit 1 (April 1, 2021, through March 31, 2022)
- (2) Unit 2 (April 1, 2021, through March 31, 2022)
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
- (1) January 1, 2021, through June 30, 2022 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
- (1) January 1, 2021, through June 30, 2022 EP03: Alert and Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
- (1) January 1, 2021, through June 30, 2022
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Unit 1 and Unit 2, use of temporary firewater pump as a temporary modification; its installation, removal, and use, as-allowed by license amendments implementing NFPA 805, on September 13, 2022
- (2) Unit 1 and Unit 2, evaluation of procedural requirements necessary to establish a backup fire suppression water supply as required by the technical requirements manual, on September 26, 2022
- (3) Unit 1, implementation of Three Mile Island action item requirements related to pressurizer heaters, on September 30, 2022
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)
- (1) The inspectors evaluated the licensees performance during heightened security awareness on July 19, 2022.
Event Report (IP Section 03.02) (1 Sample)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000368/2021-002-00, Material Defect in Primary Coolant System that Cannot be Found Acceptable Under American Society of Mechanical EngineersSection XI (ML21336A340). The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER; therefore, no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements.
INSPECTION RESULTS
Failure to Critique a Weakness During a Biennial Exercise Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000313,05000368/2022003-01 Open/Closed
[H.12] - Avoid Complacency 71114.01 The inspectors identified a Green, non-cited violation of 10 CFR 50.47(b)(14) for the licensees failure to identify and correct weaknesses in emergency response organization performance during a biennial emergency preparedness exercise conducted on August 9, 2022. Specifically, the licensee did not identify an example of performance that would have precluded effective implementation of the emergency plan if it occurred during an actual radiological emergency (untimely notification).
Description:
The inspectors observed an emergency preparedness exercise conducted on August 9, 2022 and observed the licensees formal exercise critique conducted on August 18, 2022. Based on these observations, and a review of corrective action documentation, the inspectors determined that the licensee failed to identify an emergency response organization weakness in emergency notification processes and as a result did not ensure that the weakness would be corrected.
The inspectors observed the performance of the licensees emergency response organization, including organization members in the control room simulator, Technical Support Center and the Emergency Operations Facility. During an emergency, initial and follow-up notifications to State and local officials need to be provided in a timely manner with accurate information verified by established processes.
The Arkansas Nuclear One Emergency Plan states the expectations for timeliness of initial State and local notifications. Section E, sub-section 1.0 states, Initial notification is made to the State and local authorities within fifteen
- (15) minutes after declaring an emergency.
Verification methods are used to authenticate messages to the State. State and local authorities identified in the plan include Arkansas Department of Health; Arkansas Department of Emergency Management; and Pope, Johnson, Yell, Logan, and Conway Counties. This implements 10 CFR Part 50, appendix E, section IV.D.3, which supports the 10 CFR 50.47(b)(5) planning standard.
The licensee has an automated notification system that transmits notifications to the applicable State and local organizations and provides feedback when they have acknowledged receipt. If they have not acknowledged receipt, instructions in Form 1903.011Y, Emergency Class Initial Notification Message, direct the offsite communicator on alternate verification methods (send the automated message again to facilitate acknowledging receipt, and call Arkansas Department of Health to obtain assistance in verifying that all State and local organizations received the initial notification).
At 8:19 a.m., an Alert was classified in the exercise. At 8:29 a.m., the initial notification associated with an Alert declaration was transmitted to State and local authorities.
Acknowledgement of receipt by the first authority was about 8:30 a.m., with acknowledgement by other authorities by 8:31 a.m. However, the time of acknowledgment for Conway County (via their 911 center) was 8:49 a.m. Therefore, the time of acknowledgement of the initial notification by all of the State and local authorities was 30 minutes.
The inspectors reviewed exercise player records to ascertain what took place. The players copy of Form 1903.011Y indicated that action was taken to send the notification via the automated system (step 1.2). Subsequent actions to verify that all State and local authorities acknowledged the message within 1 minute were not marked as completed. The next step marked complete is the subsequent action (step 3.0) which assumes that all authorities were verified to have received the notification.
Review of applicable notification implementing procedures and evaluator documentation was completed. Procedure EN-EP-603, Emergency Notifications, revision 1, attachment 2, says prior to step 8 verifying acknowledgement of the notification from all authorities, that [t]he 15-minute notification requirement includes the acknowledgment that all required State and local authorities have received the Initial Notification Message Form. In the evaluator logs, there were notes indicating that all of the notifications had been verified received. Discussion with licensee staff revealed that notification receipt logs were reviewed by the evaluators.
However, the fact that the log indicated that Conway County acknowledged receipt outside of 15 minutes, with no action by the communicator to ensure it was completed within that time, was missed in the evaluation process.
The inspectors reviewed documentation describing the emergency preparedness critique process to gain insights on the identification of deficiencies and weaknesses.
Procedure EN-EP-308, Emergency Planning Critiques, revision 7, section 7.2, step 4, says potential deficiencies in.personnel performance will be identified through the critique process. Further, step 9 says, in part, to [d]ocument identified weaknesses, deficiencies, or significant areas for improvement using the corrective action process. The performance objective for this topic (attachment 3, objective E.3), which sets the evaluation criteria for notification review, states, Demonstrate the ability to provide the required content for the initial notification messages accurately within the required timeframes. With the evaluation criteria clearly providing direction that evaluated success or failure relies on meeting required timeframes (for DEP PI success and 10 CFR Part 50, appendix E purposes), the inspectors concluded the licensees approach to participant performance evaluation did not appear to rigorously require that each aspect of the evaluation criteria be proven met with objective data.
The inspectors concluded the failure to demonstrate the capability to notify responsible State and local government agencies within 15 minutes after declaring an emergency precluded the effective implementation of the licensees emergency plan and constituted a weakness in emergency response organization performance.
Corrective Actions: The licensee entered this issue into the corrective action program.
Corrective Action References: condition report CR-ANO-C-2022-02351
Performance Assessment:
Performance Deficiency: The licensees failure to correct weaknesses that occurred during an exercise was a performance deficiency. This was within the licensees ability to foresee and correct. A weakness is defined in section 2.0(o) of Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, (dated September 22, 2015) as emergency response organization performance that would have prevented the effective implementation of the licensees emergency plan had the circumstances occurred. The emergency response organizations failures to notify responsible State and local government agencies within 15 minutes after declaring an emergency was a weakness requiring correction.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the ERO Performance attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The licensees ability to ensure that adequate measures will be taken to protect the health and safety of the public is degraded when weak emergency response organization performance is not corrected.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix B, Emergency Preparedness SDP. Using IMC 0609, Significance Determination Process, attachment 4, tables 1, 2, and 3 worksheets (effective date October 7, 2016); and the corresponding appendix B, table 5.14-1 and attachment 2 (issue date September 22, 2015); the performance deficiency was determined to have very low safety significance (Green) because it was a failure to comply with NRC requirements, was not a loss of planning standard function, and was not a degraded risk significant planning standard function. Although the weakness was associated with a risk significant planning standard, its associated Drill and Exercise Performance indicator opportunity was determined by the NRC to be a success, and thus treated as a degraded planning standard function. The finding was not a loss of planning standard function because the licensee appropriately critiqued other weaknesses associated with risk-significant activities and the 10 CFR 50.47(b)planning standards.
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. The finding had a cross-cutting aspect in the area of human performance associated with avoiding complacency because the licensee failed to plan for the possibility of mistakes, even while expecting successful outcomes. Specifically, the licensees critique process did not approach using the evaluation criteria with the mindset of expecting that errors can happen, and that each aspect of the evaluation criteria has to be proven met with objective data. Not approaching it from this perspective allowed the issue with initial notification timeliness, which has two clear time requirements, to go unnoticed.
Enforcement:
Violation: Title 10 CFR 50.54(q)(2), requires, in part, that a power reactor licensee follow and maintain the effectiveness of an emergency plan which meets the requirements of appendix E to 10 CFR Part 50 and the standards of 10 CFR 50.47(b).
Title 10 CFR 50.47(b)(14) requires, in part, that deficiencies identified as a result of exercises or drills are (will be) corrected. Title 10 CFR Part 50, appendix E, section IV.F.2.g requires in part that all exercises provide for formal critiques in order to identify weak or deficient areas that need correction. Any weaknesses or deficiencies that are identified in exercise critiques must be corrected.
Contrary to the above, on August 18, 2022, the licensee failed to correct deficiencies identified as a result of exercises or drills. Specifically, the licensee failed to identify an emergency response organization performance deficiency (weakness) occurring during the August 9, 2022, biennial exercise and did not ensure correction of the weaknesses. There was no actual or potential safety significance because the weak performance occurred during an exercise.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
Enforcement Discretion Enforcement Action EA-22-070: Failure to Comply with Title 10 CFR Part 37 Requirements for Radioactive Waste 71124.08
Description:
The licensee has replaced/removed their old steam generator units and their old reactor vessel heads from the containment buildings and transferred them into a large concrete storage module outside of the protected area. Although, this waste material exceeded the threshold for a category 2 quantity of radioactivity, it did not contain discrete radioactive sources, ion-exchange resins, or activated material that weighed less than 2,000 kg. Therefore, the steam generators and old reactor vessel head are considered waste material that is exempt from 10 CFR Part 37, subparts B, C, and D, but must comply with the requirements of 10 CFR 37.11(c). The inspectors observed that one of these requirements was not met.
Corrective Actions: The licensee entered the issue into the corrective action program.
Corrective Action References: condition report CR-ANO-2022-02051
Enforcement:
Severity/Significance: Minor Violation: Title 10 CFR 37.11 requires, in part, minimal security requirements for a category 2 quantity of radioactive waste that is exempt from 10 CFR Part 37, subparts B, C, and D.
Contrary to the above, from March 19, 2014 (initial compliance date with 10 CFR Part 37) to the present, the licensee failed to meet the minimal security requirements for a category 2 quantity of radioactive waste that is exempt from 10 CFR Part 37, subparts B, C, and D.
Specifically, the licensee stored a category 2 quantity of exempt waste in a large concrete storage module without meeting all the security requirements of 10 CFR 37.11(c).
Basis for Discretion: This violation met the criteria for Enforcement Discretion as described in Enforcement Guidance Memorandum (EGM) 14-001, Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52.
Failure to Implement Three Mile Island Action Item Requirements for Pressurizer Heaters Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000313/2022003-02 Open/Closed None (NPP)71152A The inspectors identified two examples of a Green, non-cited violation of the Confirmatory Order issued to Arkansas Nuclear One, Unit 1, dated January 2, 1980, for the licensees failure to implement requirements set forth in NUREG-0578, TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations. First, as-measured pressurizer ambient heat losses exceeded the predetermined pressurizer heater capacity needed to establish and maintain natural circulation at hot standby conditions when offsite power was not available. The licensee determined this was acceptable based on their conclusion that 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> was an acceptable time duration for the pressurizer heaters requirement. Second, in the event of a loss of offsite power with failure of B-train emergency power, manual operator actions outside the main control room are required to restore power to the minimum-required pressurizer heater capacity powered by A-train emergency power.
Description:
While reviewing requirements for pressurizer heater capacity, the inspectors questioned whether the minimum pressurizer heater capacity required by Unit 1 technical specification (TS) 3.4.9.b was conservative. In Modes 1, 2, and 3, TS 3.4.9.b requires a minimum of 126 kW of engineered safeguards (ES) bus powered heaters to be operable.
The inspectors reviewed the basis for limiting condition for operation 3.4.9, which states:
The pressurizer heaters are used to maintain a pressure in the RCS so reactor coolant in the loops is subcooled and thus in the preferred state for heat transport to the steam generators (SGs). This function must be maintained with a loss of offsite power. Consequently, the emphasis of this LCO is to ensure that the Engineered Safeguards (ES) bus powered heaters are adequate to maintain pressure for RCS loop subcooling with an extended loss of offsite power.
A minimum nominal capacity of 126 kW for the pressurizer heaters ensures that the RCS pressure can be maintained (Reference CR-ANO-1-2009-0158-09). Unless adequate heater capacity is available, reactor coolant subcooling may not be maintained (although the pressure control provided by the high head high pressure injection pumps is an alternate method of maintaining subcooling). Inability to control the system pressure and maintain subcooling under conditions of natural circulation flow in the primary system could lead to loss of single-phase natural circulation and decreased capability to remove core decay heat.
Three Mile Island (TMI) action item II.E.3.1 (from NUREG-0737) provided additional clarification to the requirements of NUREG-0578 that were imposed by the Confirmatory Order. Plants were required to provide a predetermined number of pressurizer heaters, powered by the redundant emergency power sources, to establish and maintain natural circulation cooling at hot standby conditions. Based on estimated pressurizer ambient heat losses for a generic plant provided by the nuclear steam system supplier, Babcock and Wilcox, the licensee selected 126 kW as an acceptable minimum TS-required heater capacity. This value was accepted by the NRC when the TS LCO 3.4.9 license amendment was issued. Additionally, action item II.E.3.1 required that any changeover of the heaters from normal offsite power to emergency onsite power is to be accomplished manually in the control room.
With respect to the first example of a violation, the inspectors questioned whether 126 kW was sufficient pressurizer heater capacity to offset the ambient heat losses from the pressurizer to the reactor building, so that adequate reactor coolant system (RCS) subcooling and natural circulation cooling could be maintained following a LOOP. The inspectors found that there was no requirement for the licensee to periodically perform a pressurizer ambient heat loss test and that the last time such a test was performed was during a 1992 refueling outage. On April 29, 1992, the licensee determined the pressurizer had a calculated ambient heat loss of 183 kW. Because the 1992 measured ambient heat loss was greater than 126 kW, the licensee developed a Licensing Position Paper (LIC-042-122), that concluded 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> was an acceptable minimum time pressurizer pressure was maintained using pressurizer heaters. The licensees basis for the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> was that there did not appear to be specific NRC regulations governing the time requirement for maintaining pressurizer heater capacity at hot standby. The licensee concluded that compliance with TMI action item II.E.3.1 did not require pressurizer heater capability to maintain hot standby indefinitely, and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> was consistent with NRCs station blackout rule, 10 CFR 50.63, where 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> was considered an acceptable time to restore offsite power if temporarily lost.
In conjunction with development of LIC-042-122, the licensee completed Calculation CALC-90-E-0038-04. This calculation evaluated the duration of time RCS subcooling would be maintained > 20 degrees F for various cases of pressurizer heater capacity, safety relief valve leakage, and measured (183 kW) ambient heat loss. For the case of the TS-minimum 126 kW heater capacity, 1 gpm of assumed safety relief valve leakage, and 183 kW of ambient heat loss, the licensee determined that subcooling margin would become <
20 degrees F in 4.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />. Therefore, since the time for subcooling margin to drop to <
20 degrees F was greater than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the as-found pressurizer ambient heat loss was acceptable.
In 1996, the licensee documented another Licensing Position Paper (LIC-96-014) regarding pressurizer heater capacity requirements. One point that was made in this position paper was that the licensee believed NRC acknowledged the use of high-pressure injection pumps for maintaining reactor coolant system pressure. The licensee based this on a quotation from the summary section of NUREG-0578. The summary of short-term recommendation item 2.1.1 states, In some designs, loss of pressurizer heaters due to a loss of offsite power requires the use of the high-pressure emergency core cooling system to maintain reactor pressure and volume control for natural circulation cooling.
The inspectors noted that the detailed description of short-term recommendation 2.1.1 provides important clarification of the use of high-pressure injection cooling:
Experience at TMI-2 has indicated that the maintenance of natural circulation capability is important to safety, including the need to maintain satisfactory natural circulation during an extended loss of offsite power. Without the availability of pressurizer heaters, it may be necessary to operate the high-pressure emergency core cooling system to maintain satisfactory natural circulation conditions. The frequency with which the high-pressure emergency core cooling system is operated may exceed the previously understood and accepted design basis. Therefore, there is a need to consider the upgrading of those pressurizer heaters and associated controls required to maintain natural circulation at hot standby conditions to a safety-grade classification in order to achieve greater reliability and to decrease the demands for operation of the emergency core cooling system. In the short term, designs should be upgraded to provide the operator with the capability to maintain natural circulation at hot standby conditions through the use of pressurizer heaters when offsite power is not available.
It should be recognized that providing this emergency power capability for a selected number of pressurizer heaters will not preclude challenges to the emergency core cooling system indefinitely after a loss of offsite power. Because of capacity limitations of the seismic Category I water supply and late-in-core-life emergency boration requirements, challenges to the emergency core cooling system may be necessary even when maintaining hot standby conditions. It is believed, however, that providing this emergency power supply capability will reduce challenges to the emergency core cooling system by facilitating natural circulation until offsite power is regained or until one of the two preceding conditions become limiting.
The inspectors concluded the detailed description of short-term recommendation 2.1.1 does not support a 4-hour limitation of the time that ES-powered pressurizer heaters are required to be operable. The recommendation clearly prefers maintaining natural circulation cooling using pressurizer heaters following a LOOP until offsite power is restored or other factors such as exhausting seismic category I water sources or emergency boration requires transition to using the emergency core cooling system. Initiating high-pressure emergency core cooling introduces additional challenges, including the potential for the electromagnetic relief valve failing to close, and extended time required to cool down the RCS without natural circulation.
The inspectors discussed the licensing history with staff from the Office of Nuclear Reactor Regulation (NRR). The NRR staff confirmed that pressurizer heater power should be capable of maintaining the required subcooling until it is no longer required by plant conditions, exclusive of using high-pressure injection for cooling. The NRR staff noted that the licensee informed the NRC by letter dated January 29, 1980, that pressurizer ambient heat loss was determined to be 82.75 kW in 1975. Therefore, the technical specification value of 126 kW would be capable of maintaining natural circulation indefinitely. The NRR staff confirmed that use of a 4-hour coping time for pressurizer heaters was not appropriate because a station blackout event is a beyond design basis event, while a LOOP is defined as an anticipated operational occurrence, which is expected to occur one or more times during the life of the plant.
With respect to the second example of a violation, the inspectors found in 2015 the licensee documented an issue with providing sufficient pressurizer heater capacity in Condition Reports CR-ANO-1-2015-02069 and CR-ANO-1-2015-02093. In the licensees design, 84 kW of pressurizer heaters are powered by A-train emergency power and 84 kW of pressurizer heaters are powered by B-train emergency power. In order to meet the minimum required 126 kW of pressurizer heater capacity, a swing set of 84 kW of pressurizer heaters is provided and may be powered from either A-train, or B-train emergency power. The licensee discovered that during a postulated loss of offsite power event with failure of B-train electrical power, the pressurizer low level interlock actuates and de-energizes the pressurizer heaters because the interlock is powered by B-train 120 Vac panel Y02. To clear the interlock, operators must perform manual switching activities at the Y01 and Y02 120 Vac instrument power panels to restore power to the alternate (A-train) source. Then, A-train pressurizer heaters may be energized and the swing set of pressurizer heaters may also be powered with A-train emergency power. The operator actions required to switch to the alternate power supply for 120 Vac panel Y02 are located outside the control room.
As discussed previously, TMI action item II.E.3.1 required any changeover of the heaters from normal offsite power to emergency onsite power to be accomplished manually in the control room. Additionally, in licensing correspondence dated November 20, 1979, the licensee informed the NRC that the supplemental heaters will be powered from the swing bus and energized manually from the control room. The inspectors considered that the manual operator actions outside the control room that were required to clear the low pressurizer level interlock to allow energizing pressurizer heaters another example of a violation of the Confirmatory Order imposing the TMI action items.
Corrective Actions: The licensee entered the issues into the corrective action program as condition report CR-ANO-2022-01541. For the first issue, the licensee has a corrective action to inspect pressurizer heater insulation during the 1R30 refueling outage (fall 2022). For the second issue, the licensee was evaluating corrective actions at the end of the inspection.
Independent of these issues, the licensee is also replacing all pressurizer heaters during the
==1R30 refueling outage to regain the original heater capacity margin.
Corrective Action References:==
condition reports CR-ANO-1-2022-00452, CR-ANO-1-2022-00512, and CR-ANO-1-2022-01541
Performance Assessment:
Performance Deficiency: The failure to have emergency-powered pressurizer heater capacity that exceeds the ambient heat losses of the pressurizer when offsite power is not available is a performance deficiency because natural circulation cooling at hot standby conditions cannot be maintained for an extended time period.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control and Equipment Performance attributes of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the performance deficiency adversely affected the objective because the design of the emergency power supply for the pressurizer heaters provided insufficient capacity to maintain reactor coolant system subcooling margin supporting natural circulation decay heat removal using the steam generators during an extended loss of offsite power (LOOP). Operators would be required to initiate high-pressure injection cooling, which challenges an engineered safety features system.
Significance: The inspectors assessed the significance of the finding using IMC 0609, appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using exhibit 2, Mitigating Systems Screening Questions, issued November 30, 2020, the inspectors determined this finding required a detailed risk evaluation. In making this determination, the inspectors made an assumption that steam generators may not be capable of performing their heat removal function if subcooling margin could not be maintained.
Therefore, using the screening questions, the finding resulted in loss of functionality of the steam generators; did not involve a single-train technical specification system; did not represent a loss of one train of a multi-train system; and did not represent the loss of function of two separate technical specification systems. However, the degraded condition represented a loss of function of the steam generators to perform their function to provide heat removal if subcooling margin could not be maintained. Therefore, a detailed risk evaluation was required. The Region IV senior reactor analyst confirmed the issue warranted a detailed risk evaluation.
The senior reactor analyst performed the detailed risk evaluation, which concluded the performance deficiency was of Green significance. The analyst used a model based on the ANO, Unit 1, SPAR model, version 8.60, which had been modified by the Idaho National Laboratory. The modified model set up the condition of a loss of only one of the class 1E safety buses coupled with a LOOP to best analyze the insufficient pressurizer heaters condition. Additionally, the SPAR model modification added a top event in the LOOP event trees which reflected the strategies to maintain adequate subcooling margin. The fault tree under this top event contained pressurizer heaters (which the performance deficiency deemed inadequate) and operator actions to maintain subcooling margin. The analyst reviewed the licensees degraded power procedure, observed a simulator session with the postulated event conditions, and interviewed operators to construct a human failure event for the failure to maintain subcooling margin using the SPAR-H human reliability analysis methodology. The analyst assigned all nominal values to the performance shaping factors to estimate the total human error probability as 1.10E-2. The final modification to the model was to adjust the recovery time of power to the deenergized class 1E bus, either by restoring a diesel generator or by restoring offsite power. The licensee had provided thermal-hydraulic analyses which modeled the response of the plant after an event which resulted in the plant being in natural circulation with no pressurizer heaters. The analyst used this analysis and relevant calculations to perform a heat balance of the pressurizer and estimated operators would have approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to recover power to a class 1E bus before adequate subcooling margin would be lost. Using these modifications, the analyst estimated that the total increase in core damage frequency was 4.3E-8/year and determined that the significance of the finding was of very low safety significance (Green).
The analyst referenced Inspection Manual Chapter 0609, Appendix H, Containment Integrity Significance Determination Process, to determine that the results of this finding were not dominated by the increase in large early release frequency and therefore would be best characterized by the increase in core damage frequency. Review of external events was not required because of the very low estimate in the increase in core damage frequency from internal events. The dominant accident sequences were losses of offsite power with the loss of one class 1E bus. Operator action and restoration of power to the deenergized class 1E bus were important mitigators to core damage.
Cross-Cutting Aspect: No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Confirmatory Order issued for Arkansas Nuclear One, Unit 1, dated January 2, 1980, Part IV required, in part, that by January 31, 1980, the licensee will implement all category A requirements referred to in part II of the Confirmatory Order.
In part II of the Confirmatory Order, the category A requirements refer to the measures set forth in NUREG-0578, TMI-2 Lessons Learned Task Force Status Report and Short-term Recommendations.
NUREG-0578, Appendix B, Table B-1, Implementation of Short-term Recommendations for Operating Plants and Plants in OL Review, states, in part, that Section 2.1.1, Emergency Power Supply Requirement, (abbreviated title) is a category A requirement.
NUREG-0578, appendix A, provides, in part, the detailed requirements to implement section 2.1.1 and the section titled, Emergency Power Supply Requirements for the Pressurizer Heaters, Power-Operated Relief Valves and Block Valves, and Pressurizer Level Indicators in PWRs (Section 2.1.1), Step 3.1.1 states, in part, that the pressurizer heater power supply design shall provide the capability to supply, from either the offsite power source or the emergency power source (when offsite power is not available), a predetermined number of pressurizer heaters and associated controls necessary to establish and maintain natural circulation at hot standby conditions. The required heaters and their controls shall be connected to the emergency buses in a manner that will provide redundant power supply capability.
Contrary to the above, since April 1992, the licensee failed to implement all the category A requirements set forth in NUREG-0578. Specifically, the licensee failed to: 1) ensure that there were sufficient pressurizer heaters powered from an emergency source, when offsite power is not available, to establish and maintain natural circulation in a hot standby condition, and 2) implement the associated controls necessary to establish and maintain natural circulation at hot standby conditions, including manual changeover from normal to emergency power in the control room, as clarified in NUREG-0737 action item II.E.3.1.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On June 30, 2022, the inspectors presented the 71111.11 technical debrief inspection results to Ralph Frederes, Training Manager, and other members of the licensee staff.
On July 6, 2022, the inspectors presented the emergency preparedness exercise scenario review inspection results to Josh Toben, Manager, Emergency Preparedness, and other members of the licensee staff.
On July 27, 2022, the inspectors presented the public radiation safety inspection results to Brian Patrick, Director, Regulatory and Performance Improvement, and other members of the licensee staff.
On August 16, 2022, the inspectors presented the 71111.11 inspection results to Ralph Frederes, Training Manager, and other members of the licensee staff.
On August 25, 2022, the inspectors presented the heat exchanger/sink performance inspection results to Douglas Pehrson, General Manager Plant Operations and acting Vice President, and other members of the licensee staff.
On September 1, 2022, the inspectors presented the emergency preparedness exercise inspection results to Joseph Sullivan, Site Vice President, and other members of the licensee staff.
On October 6, 2022, the inspectors presented the integrated inspection results to Joseph Sullivan, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-ANO-
1-2022-01109, C-2022-00099
Natural Emergencies Technical Guidelines
Procedures
OP-1203.025
Natural Emergencies
Work Orders
WO 374472, 53003533
Calculations
CALC-92-E-0021-
Class 1E 125 VDC Train 1 DC Voltage Drop Study
Corrective Action
Documents
CR-ANO-
1-2019-02364, 1-2022-00341, 1-2022-00794, 1-2022-
00883, 1-2022-01171, 1-2022-01594, C-2022-02338
Unit 1 Narrative Log
08/18/2022
M-217, Sheet 1
Emergency Diesel Generators Fuel Oil Storage
M-2217, Sheet 1
Emergency Diesel Generator Fuel Oil System
Drawings
M-2241, Sheet 3
AAC Generator System Fuel Oil Subsystem
Unit 1 Shift Turnover Sheet
08/18/2022
Unit 2 Shift Turnover Sheet
08/18/2022
Miscellaneous
Unit 2 Narrative Log
08/18/2022
1104.023
Diesel Oil Transfer Procedure
1104.032
Fire Protection Systems
1107.004
Battery and 125 VDC Distribution
203.036
Loss of 125 VDC
1307.013
Unit 1 Class 1E Battery Charger Load Test
1307.063
Unit 1 D06 and D07 Battery Surveillance
2104.037
Alternate AC Diesel Generator Operating
Procedures
2305.018
Underground EDG F.O. Tank 2T-57A/B Recirculation and
Cleanup
Work Orders
WO 2939683, 52966335
Corrective Action
Documents
CR-ANO-
1-2022-00129, 2-2022-01361, 2-2022-01376, 2-2022-
01454, 2-2022-01486, C-2022-01986, C-2022-02535
FP-110, Sheet 1
Fire Zones Intake Structure
FZ-1043, Sheet 1
Fire Zone Detail Cable Spreading Room
Drawings
FZ-2098-L
Fire Zone Detail CPC Room
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Unit 1 Pre-Fire Plans
Fire Plans
Unit 2 Pre-Fire Plans
Miscellaneous
Unit Common Pre-Fire Plans
Control of Hot Work and Ignition Sources
Control of Combustibles
Equipment Important to Emergency Response
Procedures
Waste Management Program
Corrective Action
Documents
CR-ANO-
1-2022-01077
Miscellaneous
Final 1E-28B Eddy Current 202207 Inage Report
07/2022
Work Orders
91-E-0099-14
ECP Peak Temperature and Inventory Analysis
Calculations
ECP Peak Temperature and Inventory Analysis
Corrective Action
Documents
CR-ANO-
1-2019-00819, 1-2019-04166, 1-2020-00123, 1-2020-
00520, 1-2020-00960, 1-2020-01465, 1-2021-00008, 1-
21-00492, 1-2021-02270, 1-2021-03054, 1-2021-
03055, 1-2021-03315, 1-2022-00720, 2-2017-00968, 2-
2017-03766, 2-2017-04493, 2-2019-00780, 2-2020-
03401, 2-2020-03470, 2-2021-00457, 2-2021-00739, 2-
21-01893, 2-2021-02772, 2-2021-02799, 2-2022-
00505, 2-2022-00918, C-2017-03550, C-2018-03746, C-
2019-00994, C-2019-04595, C-2020-01448, C-2020-
2049, C-2020-02050, C-2020-02439, C-2021-00303, C-
21-00352, C-2021-00959,
21018_POND.dgn,
Sheet 1
Hydrographic Mapping of Emergency Cooling Pond,
Arkansas Nuclear One Facility
07/20/2021
C-65
Emergency Cooling Reservoir
Drawings
C-69, Sht. 1
Emergency Cooling Pond - Original Spillway
DOCUMENT 2021 ECP HYDROGRAPHIC SURVEY
Engineering
Changes
ER-ANO-1998-
0738-002
Emergency Cooling Pond Remote Level Indication
06/26/1998
STM 1-42
Arkansas Nuclear One Unit 1 Service and Auxiliary
Cooling Water Systems, System Training Manual
71111.07SIX
Miscellaneous
STM 2-42
Arkansas Nuclear One Unit 2 Service Water & Auxiliary
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Cooling Water Systems, System Training Manual
ULD-1-SYS-10
Arkansas Nuclear One Upper Level Document, ANO Unit
Service Water System
ULD-2-SYS-10
Arkansas Nuclear One Upper Level Document, ANO Unit
Service Water System
Unit 1 Q4-2021
Unit 1 - Service Water - System Health Report
2/17/2022
Unit 2 Q4-2021
Unit 2 System Health Report
2/17/2022
CR-ANO-2-2021-
03502
Service Water Pipe Leak on Service Water Supply Piping
to 2E-35B SDC HX (2HBC-43-14")
CR-ANO-2-2021-
03595
Service Water pipe leak on Service Water Supply Piping
to 2VCC-2C/D Containment Cooler Supply Line (2HBC-
69)
Operability
Evaluations
CR-ANO-C-2022-
841
Service Water Pipe Leak on Service Water Loop I Supply
Piping (HBD-14-18")
OP-1203.030
Loss of Service Water
OP-2203.022
Loss of Service Water
OP-1052.007
Secondary Chemistry Monitoring
OP-1104.029
Service Water and Auxiliary Colling System - Service
Water Pump P-4B Test
21
OP-1104.029
Service Water and Auxiliary Cooling System - Service
Water Boundary Valve Leak Test
2
OP-1106.006
Emergency Feedwater Pump Operation - EFW Service
Water Suction Piping Flush
116
OP-1305.007
RB Isolation and Miscellaneous Valve Stroke Test -
Supplement 2 - Valve Stroke test RCS Less Than or
Equal to 200 degrees Fahrenheit.
OP-1608.007
Eradication of Fish and Algae Monitoring at the
Emergency Cooling Pond
OP-1618.029
Sampling Unit 1 Service Water and Auxiliary Cooling
Water
OP-1628.0009
Operation of the Unit 1 Service Water Chemical Injection
System
Procedures
OP-2104.029
Service Water System Operations - Green Train Service
Water Valve Stroke.
20
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
OP-2618.026
Sampling Unit 2 Service Water and Auxiliary Cooling
Water
OP-2628.013
Operation of Unit 2 Service Water Corrosion Inhibitor
Injection System
ULD-1-SYS-10
Arkansas Nuclear One Upper Level Document, ANO Unit
Service Water System
Work Orders
299896, 52033306, 52508906, 52593445, 52612597,
2652762, 52715947, 52734618, 52768902, 52819523,
2831100, 52839272, 52839275, 52861027, 52868532,
2888168, 52889887, 52892417, 52897607, 52903447,
2933340, 52938930, 52943308, 52972909, 52974640,
2915901, 52921381, 52936889, 52942118, 52957193,
2962186
91-E-0139-01
Heatup Rate of Room 2024 (2P7A) With No Room
Cooling
91-R-2013-01
Service Water Performance Testing Methodology
2-D-2011-16
AAC [Alternate AC] Generator Engine Cooling Water
System Evaluation
2-D-2011-24
AAC [Alternate AC] Generator System Design Pressures
and Temperature for Piping and Valves
2-E-0079-01
Determination of SW-Cooled Room Heat Loads Under
Various Operating Conditions
93-R-2016-01
ANO-2 AB Limiting Component Qualification
Temperatures
Calculations
94-E-0095-12
Room 2024 Heat Load Eval [Evaluation]
Corrective Action
Documents
CR-ANO-
2-2009-01374, 2-2017-01566, 2-2022-00109, C-2021-
01689, C-2022-01802, C-2022-01931,
Corrective Action
Documents
Resulting from
Inspection
CR-ANO-
2-2022-01648, C-2022-02364, C-2022-02365, C-2022-
2366
0189549-001,
Sheet 1
Nuclear Containment Cooling Coil
Drawings
6600-M224-18-3
American Air Filter Company, Inc. - H22MPACFYA
06/05/1975
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
914100
28-64-14W5-14C Cooling Coil Approval Drawing
M-2210, Sheet 3
Piping & Instrument Diagram, Service Water System
M-2241, Sheet 1
Piping & Instrument Diagram, AAC Generator System,
Engine Cooling Water Subsystem
M-2262, Sheet 2
Piping & Instrument Diagram, Air Flow Diagram, Heating
Ventilating Air Conditioning, Aux. [Auxiliary] Bldg.
[Building] Radwaste [Radioactive Waste] Area
M-2262, Sheet 3
Piping & Instrument Diagram, HVAC Control Diagram,
Auxiliary Building Radwaste [Radioactive Waste] Area
M-2423, Sheet 7
Functional Description & Logic Diagram, Auxiliary Building
Vent & Air Conditioning System
Excess Airflow Effects on AB Room Cooler Thermal
Performance and Other Impacts (Reference CR-ANO-2-
2017-01566) Including Changes to SW Methodology
Report Per SPD-03 (Reference CR-ANO-C-2015-2834 CA
164)
000
Engineering
Changes
ANO-2 EFW Pump Woodward Governor Controls
Upgrade 2R28
000
NES-13
Environmental Qualification - Environmental Service
Conditions
SEP-HX-ANO-001
Arkansas Nuclear One (ANO) Heat Exchanger Program,
Entergy Nuclear Engineering Programs
005
STM 2-19-2
Arkansas Nuclear One, Unit 2, System Training Manual,
Emergency Feedwater and Auxiliary Feedwater Systems
STM 2-33
Arkansas Nuclear One Unit 2, System Training Manual,
Alternate AC Diesel Generator
TD A220.0140
Installation, Operation, and Maintenance for Air Handling
Units Model YA
Miscellaneous
TD S642.0030
Operation and Maintenance Manual For Southworth-
Milton Caterpillar 3612 Engine Generator Cooling System
2104.037
Alternate AC [Alternating Current] Diesel Generator
Operations
038
203.012E
Annunciator 2K05 Corrective Action
043
Procedures
Heat Exchanger Performance and Condition Monitoring
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
50969719, 51055559, 52396732, 52404174, 52437092,
2437320, 52437580, 52505284, 52530118, 52530982,
2548680, 52570769, 52644855, 52653097, 52668327,
2668754, 52777542, 52783236, 52798794, 52830166,
2836717, 52888105, 52901401, 52912611, 52916701,
2926048, 53001600
Miscellaneous
Unit 2 Annual Operations Exam Results Summary
08/02/2022
Corrective Action
Documents
CR-ANO-
1-2021-00320, 2-2020-02523, 2-2020-02611, 2-2020-
03053, C-2019-01137, C-2019-02349, C-2019-03346, C-
20-00033, C-2020-00493, C-2020-00495, C-2020-
209, C-2020-01960, C-2020-02480, C-2020-02706, C-
20-02931, C-2022-01074, C-2022-01231, C-2022-
251, WTANO-2020-42, WTANO-2020-154, WTANO-
20-314, WTANO-2021-285, WTANO-2022-243
Staff Crew 1 Remediation Package
07/01/2021
Licensed Operator #1 Remediation Package
07/01/2021
Licensed Operator #2 Remediation Package
2/12/2021
Unit 2 2022 LOR Biennial Exam Security Plan
06/09/2022
Cycle 2206 Biennial Written Exam R1 (RO)
06/24/2022
Cycle 2206 Biennial Written Exam S1 (SRO)
06/24/2022
22 NRC Annual Operating Exam Overlap Tracker
06/23/2022
22 NRC Operating Test Overall Overlap
06/23/2022
22 Annual Operating Exam Week 1
05/23/2022
22 Annual Operating Exam Week 2
05/23/2022
Reactivation Package #1
11/26/2021
Reactivation Package #2
03/21/2022
Reactivation Package #3
01/12/2022
Reactivation Package #4
11/03/2021
Reactivation Package #5
07/12/2021
ANO2 012521 Simulator Review Committee Minutes
01/25/2021
ANO2 022120 Simulator Review Committee Minutes
2/21/2020
ANO2 06622 Simulator Review Committee Minutes
06/06/2022
ANO2 071320 Simulator Review Committee Minutes
07/13/2020
Miscellaneous
ANO2 120519 Simulator Review Committee Minutes
2/05/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ANO2 121521 Simulator Review Committee Minutes
2/15/2021
Simulator Modifications Package
04/29/2022
Simulator Open Work Items Summary
04/29/2022
Cycle 29 Simulator Operability Test A2REC-SIM-ANSI
DG-TRNA-015-
CORETEST
Simulator Core Reload Acceptance Test
05/28/2021
1063.008
Operations Training Sequence
DG-TRNA-015-
EXAMSEC
Simulator Exam Security Guidelines
DG-TRNA-015-
SIMCONTROL
Simulator Modification Control
DG-TRNA-217-
EXAMSECURITY
Exam Security
Operations Training Program Description
Training Oversight Program
Simulator Configuration Control
Conduct of Simulator Training
Accredited Training Program Assessment Process
Training and Qualification Curriculum
Examination Security
TQF-201-IM05
Remedial Training Plan
TQF-210-DD03
LOR Simulator Crew Performance Evaluation Report
Procedures
TQF-217-SEC
Exam Security Agreement
Corrective Action
Documents
CR-ANO-
1-2020-03391, 1-2020-03392, 1-2021-00455
OP-1102.004
Power Operation
OP-1105.004
Integrated Control System
OP-1304.125
Unit 1 RPS-A/CRD Breaker Trip Test
Procedures
OP-1304.127
Unit 1 RPS-C/CRD Breaker Trip Test
Work Orders
Calculations
CALC-ANOC-SE-
2-00002
Maintenance Rule 10CFR50.65 (a)(3) Periodic
Assessment 1 July 2020 to 31 December 2021
Corrective Action
CR-ANO-
1-2022-01446, 1-2022-01509, 2-2022-00217, 2-2022-
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
00801, 2-2022-01743, 2-2022-01793, C-2022-01159
Miscellaneous
ULD-2-SYS-20
ANO-2 120 VAC System
Maintenance Rule (a)(1) Process
Maintenance Rule Periodic Assessment
Corrective Action Program
EN-LI-108-01
CFR 21 Evaluations and Reporting
OP-1416.043
K-Line Circuit Breaker Overhaul
OP-2107.001
Electrical System Operations
138
Procedures
OP-2107.003
Inverter and 120VAC Electrical System Operation
Work Orders
WO 407586, 571438, 578812
Unit 2 Daily Station Logs
07/20/2022
Miscellaneous
CALC-ANOC-SE-
2-00002
Maintenance Rule 10CFR50.65(a)(3) Periodic
Assessment 1 July 2021 to 31 December 2021
COPD-024
Risk Assessment Guidelines
On Line Risk Assessments
OP-2104.001
Safety Injection Tank Operations
OP-2306.005
Maintenance Surveillance on Unit 2 Emergency Diesel
Procedures
OP-901-102
308
Work Orders
WO 571833, 52953788, 53000929
Corrective Action
Documents
CR-ANO-
1-2016-00051, 1-2019-00338, 1-2019-01318, 1-2019-
01336, 1-2019-03680, 1-2019-03815, 1-2022-01182, 2-
2019-02104, 2-2019-02260, 2-2020-00456, C-2020-
00636, C-2021-01689, C-2022-01802,
E-195
Schematic Diagram - Limit and Torque Switch
E-416
Schematic Diagram - Intake Structure Sluice Gate
Drawings
M-232
Decay Heat Removal System
111
Motor Operated Valve (MOV) Test Data Review
SEP-ANO-1-IST-1
ULD-0-SYS-19
ANO Unit 1 and Unit 2 Alternate AC Generator System
Miscellaneous
ULD-1-SYS-10
ANO Unit 1 Service Water System
Procedures
OP-1104.029
Service Water and Auxiliary Cooling System
27
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
OP-1305.007
RB Isolation and Miscellaneous Valve Stroke Test
OP-1403.014
Maintenance of Rotork Actuators
OP-1412.083
Rotork Valves and Valvops Inspection and Lubrication
OP-2104.037
Alternate AC Diesel Generator Operation
Work Orders
WO 518906, 528622, 533729, 53001600,
CALC-86-D-1006-
SW Bays Ultrasonic Level Transmitter
CALC-89-E-0044-
ANO-1 SW Pump NPSH and Submergence Requirements
Calculations
CALC-91-E-0099-
ECP Peak Temperature and Inventory Analysis
Corrective Action
Documents
CR-ANO-
1-2022-00327, 1-2022-00380, 1-2022-00720, 1-2022-
00844, 1-2022-01157, 1-2022-01366, 2-2022-00801, 2-
22-01489, 2-2022-01716, 2-2022-01717
Drawings
M-209
Circ Water, Service Water & Fire Water Intake Structure
Equipment
115
Miscellaneous
ULD-2-SYS-20
ANO-2 120 VAC System
MI-005-473
Control Element Drive Mechanism Control System
Calibration
306
OP-1104.004
Decay Heat Removal Operating Procedure
136
OP-1104.029
Service Water and Auxiliary Cooling System
27
OP-2104.036
Emergency Diesel Generator Operations
103
OP-2104.039
HPSI System Operation
OP-2107.003
Inverter and 120 VAC Electrical System Operation
Procedures
OP-903-005
Control Element Assembly Operability Check
Work Orders
Work Order 571833, 576215, 578812, 52715847, 52954787,
2963940, 52966335, 52982070, 53004628
Corrective Action
Documents
CR-ANO-
1-2022-01103, 1-2022-01352, 1-2022-01503,
Miscellaneous
1R30 Outage Risk Assessment Team Report, Revision 1
of Outage Schedule
09/21/2022
COPD-024
Risk Assessment Guidelines
Procedures
OP-1015.048
Shutdown Operations Protection Plan
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
OP-1052.030
ANO Spill Prevention, Control, and Countermeasure Plan
Corrective Action
Documents
CR-ANO-
1-2022-00083, 1-2022-00654, 1-2022-00881, 1-2022-
00911, 2-2021-03775, 2-2022-00175, 2-2022-00307
Miscellaneous
Unit 1 Station Log
08/02/2022
1304.125
Unit 1 RPS-A/CRD Breaker Trip Test
1304.127
Unit 1 RPS-C/CRD Breaker Trip Test
OP-1104.036
Emergency Diesel Generator Operations
OP-1304.205
Unit 1 EFIC Channel A Monthly Test, SG Pressure
Greater Than 750 PSIG
OP-2104.001
Safety Injection Tank Operations
Procedures
OP-2304.043
Unit 2 Plant Protection System Channel C Field
Calibration
Work Orders
WO 2957857, 53007903, 53007907, 53008194, 53009747
Corrective Action
Documents
CR-ANO-
1-2020-00324, 1-2020-00930, 1-2020-01116, 2-2021-
00641, C-2020-00319, C-2020-00392, C-2021-00292, C-
21-01170, C-2021-02119, C-2021-02351, C-2021-
2872, C-2022-02186, C-2022-02190, C-2022-02191, C-
22-02194, C-2022-02196, C-2022-02199, C-2022-
200, C-2022-02203, C-2022-02204, C-2022-02222, C-
22-02224, C-2022-02227, C-2022-02227, C-2022-
228, C-2022-02231, C-2022-02233, C-2022-02235, C-
22-02236
Corrective Action
Documents
Resulting from
Inspection
CR-ANO-
C-2022-02351, C-2022-02492, C-2022-02493
1903.011
Emergency Response/Notifications
1903.030
Evacuation
1904.002
Offsite Dose Projections
Drills and Exercises
Emergency Planning Critiques
Emergency Notifications
0, 1
Emergency Operations Facility (EOF) Operations
Procedures
Technical Support Center (TSC) Operations
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Declared Emergency Recovery and Re-entry
Human Performance Traps & Tools
Procedure and Work Instruction Use and Adherence
10CFR50.54(q)(3) Evaluation - Procedure/Document
Number: OP-1903.010, Revision: 60,
Equipment/Facility/Other: ANO Units 1 and 2; Title:
Emergency Action Level Classification
05/04/2022
10CFR50.54(q)(3) Screening - Procedure/Document
Number: OP-1903.010, Revision: 60,
Equipment/Facility/Other: ANO Units 1 and 2; Title:
Emergency Action Level Classification
05/24/2022
0CAN031801
License Amendment Request; Adoption of Emergency
Action Level Schemes Pursuant to NEI 99-02, Revision 6;
Arkansas Nuclear One, Unit 1 and Unit 2; Docket Nos. 50-
313, 50-368 and 72-13; License Nos. DPR-51 and NPF-6
03/28/2018
0CAN062201
Emergency Plan Implementing Procedure Revision,
Arkansas Nuclear One - Units 1 and 2; Docket Nos. 50-
313, 50-368, and 72-13; License Nos. DPR-51 and NPF-6
06/16/2022
Miscellaneous
0CAN091801
Response to Request for Additional Information Related to
the Application for Adoption of Emergency Action Level
Schemes Pursuant to NEI 99-01, Revision 6; Arkansas
Nuclear One, Units 1 and 2; Docket Nos. 50-313 and 50-
368; License Nos. DPR-51 and NPF-6
09/17/2018
1903.010
Emergency Action Level Classification
Procedures
Emergency Planning 10CFR50.54(q) Review Program
Miscellaneous
Arkansas Nuclear One Emergency Plan
OP-1903.010
Emergency Action Level Classification
OP-1903.011
Emergency Response/Notifications
Procedures
OP-1903.082
Operational Support Center (OSC) Activation
Miscellaneous
0CAN062203
Emergency Plan Full Participation - Exercise Drill
Scenario; Arkansas Nuclear One - Units 1 and 2; NRC
Docket Nos. 50-313 and 50-368, and 72-13; Renewed
Facility Operating License Nos. DPR-51 and NPF-6
06/07/2022
Procedures
1903.010
Emergency Action Level Classification
57, 59
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
OP-1903.011
Emergency Response/Notification
1413.440
Unit 1 Process Radiation Monitor Test (Draft)
06/29/2022
3.9 Liter
Detector 2 - 3.9 Liter Jug
05/18/2021
mm Filter
Detector 1 - 47 mm Fiber Filter, Shelf 1
05/23/2021
2809727
Unit 1 Area Radiation Monitoring System Calibration
2/06/2020
2883846
Unit 1 Liquid Radwaste Instrument Calibration
10/21/2020
2895497
Calibration of All Unit 1 Process Radiation Monitors
04/01/2021
2898182
Unit 1, Calibration of Radwaste Area Monitor - RX-9825
(SPING 2)
08/20/2021
2918732
Unit 1, High Range Containment Radiation Monitor
Calibration - RITS-8060
08/26/2021
2925843
Calibration of Emergency Penetration 2RX-9835 (SPING
8)
10/28/2021
2938814
Unit 2 High Range Containment Radiation Monitor
Calibration - 2RE-8925
10/22/2021
8890
Portable Instrument Calibration Data Sheet
08/03/2021
AMS-031
Eberline Model AMS-4 Beta Particulate Air Monitor
Calibration
2/08/2022
ARGOS-002
Operation and Calibration of the ARGOS-5AB Personnel
Contamination Monitor
07/19/2021
ARGOS-005
Operation and Calibration of the ARGOS-5AB Personnel
Contamination Monitor
01/18/2022
Charcoal Cartridge
Detector 1 - F&J Charcoal Cartridge, Shelf 1
05/16/2021
CHP-C-033
Portable Instrument Calibration Data Sheet
08/24/2021
CHP-DR-040
Portable Instrument Calibration Data Sheet
03/16/2022
CHP-DR-322
Portable Instrument Calibration Data Sheet
04/05/2022
CHP-N-021
Portable Instrument Calibration Data Sheet
2/14/2021
CHP-TEL043
Portable Instrument Calibration Data Sheet
10/21/2021
FASTSCAN 1
Calibration of the "FASTSCAN 1" whole body counting
system at the Entergy Arkansas Nuclear One station
05/10/2022
Gas Marinelli
Detector 2 - Gas Marinelli, Shelf 1
05/19/2021
GEM-002
Operation and Calibration of the Canberra GEM-5
05/09/2022
Calibration
Records
GSAM-007
Operation and Calibration of Gamma Scintillation Tool
2/20/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Monitors
HP-AS-133
Portable Instrument Calibration Data Sheet
03/16/2022
Corrective Action
Documents
CR-ANO-
2-2022-00238, C-2019-03512, C-2020-01755, C-2020-
2085, C-2020-02086, C-2021-00099, C-2021-00252, C-
21-02313
Corrective Action
Documents
Resulting from
Inspection
CA-ANO-
C-2022-01760, C-2022-01789, C-2022-01890
CHP-DR-325
Instrument Response Check Failure Review
05/05/2022
CHP-DR-338
Instrument Response Check Failure Review
04/13/2022
CHP-DR-382
Instrument Response Check Failure Review
03/21/2022
Offsite Dose Calculation Manual
PMCD 2002-3500-
P101
Calibration Frequency Change Request for Unit 1 Area
Radiation Monitors
10/29/2003
PMCD 2002-3755-
P 101
Calibration Frequency Change Request for Unit 1 Process
Radiation Monitors
11/04/2003
RAMGAM-28
Instrument Response Check Failure Review
06/22/2022
Miscellaneous
Unit 1 FSAR
Final Safety Analysis Report - Unit 1
1304.027
Unit 1 Effluent Process Radiation Monitor Calibration
1304.028
Unit 1 Area Radiation Monitoring System Calibration
1413.440
Unit 1 Process Radiation Monitor Test
1601.488
Eberline Model AMS-4 Beta Particulate Air Monitor
Calibration
1604.004
Liquid Scintillation Counting For Gross Beta and Tritium
Measurements
1903.010
Emergency Action Level Classification
EN-CY-110-01
Apex-Gamma Counting Operations
Preventive Maintenance Component Classification
Preventative Maintenance Program
Radiation Protection Instrument Control
Procedures
Operation and Calibration of Gamma Scintillation Tool
Monitors
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Operation and Calibration of the Canberra GEM-5
Operation and Calibration of the ARGOS-5AB Personnel
Contamination Monitor
Operation and Calibration of the CRONOS Contamination
Monitor
EN-RP-317-05
Calibration of Extendable Dose Rate Instruments
EN-RP-317-07
Calibration of Portable Count Rate Instruments
EN-RP-317-10
Calibration of Portable Dose Rate Instruments
LO-ALO-2021-
00056
Radiation Inspection - Radiation Monitoring
Instrumentation, Radioactive Solid
Waste Processing & Radioactive Material Handling,
Storage, & Transportation
2/15/2022
Self-
Assessments
QA-2/6-2021-
ANO-1
Quality Assurance Audit Report: Chemistry, Effluents and
Environmental Monitoring
09/16/2021
Corrective Action
Documents
CR-ANO-
2-2021-00221, C-2020-02267, C-2021-00368, C-2021-
00610, C-2021-02154, C-2021-02566, C-2021-02567, C-
22-00202, C-2022-00440
CR-ANO-
1-2022-01031, C-2022-01757, C-2022-01783, C-2022-
01784, C-2022-01794, C-2022-01889, C-2022-02051
Corrective Action
Documents
Resulting from
Inspection
CR-HQN-
22-01174
List of Radioactive Material Storage Locations
06/20/2022
Leak Testing Sources
06/16/2022
Miscellaneous
FCBT-MPC-
HAZSEC
HAZMAT-DOT Shipping for Individuals with
Indirect/Limited Responsibilities
1601.502
Radioactive Material Control at Radwaste
1601.505
Processing of Spent Radioactive Resin
1601.506
Radioactive Waste Management Program Surveillances
Security Impact Review Program
Radioactive Material Control
Radioactive Waste Management
Radioactive Waste Tracking Procedure
Scaling Factors
Procedures
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Integrated Transportation Security Plan
Radioactive Shipment Accident Response
21-03979
21 Tri Nuk
2/10/2022
Radiation
Surveys
21-08936-1
21 Dry Active Waste
01/31/2022
Self-
Assessments
LO-ALO-2021-
00056
Radiation Inspection - Radiation Monitoring
Instrumentation, Radioactive Solid Waste Processing &
Radioactive Material Handling, Storage, & Transportation
2/15/2022
20 Shipping List
21 Shipping List-21
22 Shipping List-22
RSR 20-061
Uniform Low-Level Radioactive Waste Manifest Shipping
Package
05/28/2020
RSR 20-084
Uniform Low-Level Radioactive Waste Manifest Shipping
Package
08/26/2020
RSR 20-093
Uniform Low-Level Radioactive Waste Manifest Shipping
Package
09/16/2020
RSR 21-091
Uniform Low-Level Radioactive Waste Manifest Shipping
Package
09/09/2021
Shipping Records
RSR 21-109
Uniform Low-Level Radioactive Waste Manifest Shipping
Package
10/22/2021
Semi Annual Leak Test of Sealed Sources
10/05/2021
Work Orders
Semi Annual Leak Test of Sealed Sources
03/31/2022
Corrective Action
Documents
CR-ANO-
C-2022-01328, C-2022-01848
EOF 2nd Quarter - PI Drill Green Team, Entergy
Corporation, Arkansas Nuclear One, 6/17/2021
07/8/2021
Performance Analysis, CR-ANO-C-2022-1328, Event
Title: Key ERO Performance PI Calculation Error, Event
Date: April 1, 2021 - June 30, 2022
07/13/2022
ANO-1 and ANO-2 NRC Performance Indicator
Technique/Data Sheets - Mitigating Systems
Q2-2021
ANO-1 and ANO-2 NRC Performance Indicator
Technique/Data Sheets - Mitigating Systems
Q3-2021
71151
Miscellaneous
ANO-1 and ANO-2 NRC Performance Indicator
Q4-2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Technique/Data Sheets - Mitigating Systems
ANO-1 and ANO-2 NRC Performance Indicator
Technique/Data Sheets - Mitigating Systems
Q1-2022
ANO-1 and ANO-2 NRC Performance Indicator
Technique/Data Sheets - Barrier Integrity
Q2-2021
ANO-1 and ANO-2 NRC Performance Indicator
Technique/Data Sheets - Barrier Integrity
Q3-2021
ANO-1 and ANO-2 NRC Performance Indicator
Technique/Data Sheets - Barrier Integrity
Q4-2021
ANO-1 and ANO-2 NRC Performance Indicator
Technique/Data Sheets - Barrier Integrity
Q1-2022
ANO-1 and ANO-2 NRC Performance Indicator
Technique/Data Sheets - Mitigating Systems
Q2-2022
KLD TR-1208
Arkansas Nuclear One Alert and Notification System
(ANS) Design Report
09/25/2020
EN-FAP-EP-005
Emergency Preparedness Performance Indicators
Regulatory Performance Indicator Process
Regulatory Performance Indicator Process
Procedures
Emergency Planning Performance Indicators
Corrective Action
Documents
CR-ANO-
1-2009-0158, 1-2015-2069, 1-2015-2093, 1-2022-0452, 1-
22-0512, 1-2022-01370, 1-2022-01375, 1-2022-01540,
1-2022-01541, C-2021-01042, C-2021-01163, C-2021-
2500, C-2021-02596, C-2021-02666, C-2022-01777, C-
22-02820, C-2022-2827, C-2022-02834
Standing Order: Backup Suppression Pump for Removing
a Fire Pump from Service
ANO Unit No. 2 - Issuance of Amendment Regarding
Transition to a Risk-Informed, Performance-Based Fire
Protection Program In Accordance With 10 CFR 50.48(c)
2/18/2015
Miscellaneous
ANO Unit No. 1 - Issuance of Amendment Regarding
Transition to a Risk-Informed, Performance-Based Fire
Protection Program In Accordance With 10 CFR 50.48(c)
10/07/2016
OP-1104.032
Fire Protection Systems
Procedures
OP-1104.032
Fire Protection Systems
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
OP-1203.048
Security Event
CR-ANO-
2-2021-02062, 2-2021-02594, 2-2021-03284
Corrective Action
Documents
CR-ANO-
C-2022-01939, C-2022-01969, C-2022-01972, C-2022-
01975
ARKANSAS NUCLEAR ONE, UNIT 2 - APPROVAL OF
REQUEST FOR ALTERNATIVE FROM CERTAIN
REQUIREMENTS OF THE AMERICAN SOCIETY OF
MECHANICAL ENGINEERS BOILER AND PRESSURE
VESSEL CODE (EPID L-2021-LLR-0084) DATED APRIL
7, 2022(ADAMS Accession Nos. ML22073A094,
04/07/2021
Relief Request ANO2-R&R-012 Support the Repair of the
Reactor Vessel Closure Head Penetration #46 (ADAMS
Accession Nos. ML21283A001, ML21283A002)
10/10/2021
Relief Request ANO2-RR-21-002, Half-Nozzle Repair of
Reactor Vessel Closure Head Penetration #46 (ADAMS
Accession No. ML21309A007)
11/05/2021
Response to Request for Additional Information
Concerning Relief Request ANO2-RR-21-002 Support the
Repair of the Reactor Vessel Closure Head Penetration
- 46 (ADAMS Accession No. ML21312A017)
11/07/2021
LER 05000368/2021-002-00, Material Defect in Primary
Coolant System that Cannot be Found Acceptable Under
American Society of Mechanical EngineersSection XI
(ADAMS Accession No. ML21336A340)
2/01/2021
Miscellaneous
Relief Request ANO2-RR-21-002, Half-Nozzle Repair of
Reactor Vessel Closure Head Penetration #46 - Submittal
of Analyses (ADAMS Accession Nos. ML21344A068,
ML21344A069, ML21344A070, ML21344A071)
2/10/2021
Procedures
Security Reporting Requirements
15