IR 05000313/2023003
| ML23324A212 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/21/2023 |
| From: | John Dixon NRC/RGN-IV/DORS/PBD |
| To: | Pehrson D Entergy Operations |
| References | |
| IR 2023003 | |
| Download: ML23324A212 (39) | |
Text
November 21, 2023
SUBJECT:
ARKANSAS NUCLEAR ONE - REVISED INTEGRATED INSPECTION REPORT 05000313/2023003 AND 05000368/2023003 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION INSPECTION REPORT 07200013/2023001
Dear Doug Pehrson:
On September 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Arkansas Nuclear One. The results of this inspection were originally issued in a report, dated November 13, 2023 (Agencywide Document Access and Management Systems (ADAMS) Accession No. (ML23313A096).
The NRC staff subsequently determined that the Performance Assessment section of the Green, non-cited violation (NCV)05000313/2023003-02, Failure to Maintain FLEX Equipment Consistent with the Requirements of 10 CFR 50.155(c)(1) was not included in the report. This error was due to an administrative oversight. Consistent with NRC processes, the Performance Assessment section has been added and this report is being reissued in whole.
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 Reactor Projects Branch D Division of Operating Reactor Safety Signed by Dixon, John on 11/21/23 Docket Nos. 05000313, 05000368, 07200013 License Nos. DPR-51, NPF-6
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000313, 05000368, and 07200013
License Numbers:
Report Numbers:
05000313/2023003, 05000368/2023003, and 07200013/2023001
Enterprise Identifier:
I-2023-003-0007 and I-2023-001-0015
Licensee:
Entergy Operations, Inc.
Facility:
Arkansas Nuclear One
Location:
Russellville, AR
Inspection Dates:
July 1, 2023, to September 30, 2023
Inspectors:
L. Brookhart, Senior Spent Fuel Storage Inspector
R. Bywater, Senior Resident Inspector
T. DeBey, Resident Inspector
T. Farina, Senior Operations Engineer
J. Freeman, Spent Fuel Storage Inspector
S. Hedger, Senior Emergency Preparedness Inspector
R. Kopriva, Senior Project Engineer
K. Murphy, Operations Engineer
B. Tharakan, Technical Assistant
R. Williams, Operations Engineer
Approved By:
John L. Dixon, Jr., Chief
Reactor 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 Maintain FLEX Equipment Consistent with the Requirements of 10 CFR 50.155(c)(1)
Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000313/2023003-02 Open/Closed
[H.2] - Field Presence 71111.12 The inspectors identified a Green, non-cited violation of 10 CFR 50.155(c)(1), Mitigation of Beyond-Design-Basis Events, when the licensee failed to maintain equipment of sufficient capacity and capability to implement strategies to maintain and restore core cooling, containment, and spent fuel cooling capabilities following a beyond-design-basis external event. Specifically, the licensee failed to implement a fuel oil quality strategy for FLEX diesel-driven equipment, and consequently, FLEX diesel generator K12 failed a surveillance test.
Failure to Conduct Drills in Accordance with the Site Emergency Plan Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000313,05000368/2023003-03 Open/Closed
[H.13] -
Consistent Process 71114.05 The inspectors identified a Green non-cited violation of 10 CFR 50.54(q)(2) associated with the licensees failure to follow their emergency plan. Specifically, the licensee failed to follow Arkansas Nuclear One Emergency Plan, revisions 46 and 47, section N.2.4, which requires annual radiological monitoring drills. The licensee failed to conduct correctly scoped radiological monitoring drills in 2021 and 2022 by not including sampling activities both onsite and offsite.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000313,05000368/2023003-01 Use and Acceptance of the Holtec Canister with the CBS Variant Design Change 60854 Open
PLANT STATUS
Unit 1 began the inspection period at approximately 96 percent power because of elevated lake temperatures and having only two circulating water pumps available. Unit 1 operators raised power to 100 percent on July 8, 2023, when lake temperature allowed full power operation. On July 20, 2023, lake temperatures became elevated again and Unit 1 operators began to reduce power. Power was stabilized at approximately 95.5 percent. Unit 1 operators restored the unit to full power on July 22, 2023, when lake temperature allowed full power operation. Unit 1 remained at or near full power for the remainder of the inspection period.
Unit 2 began the inspection period at full power. On September 10, 2023, Unit 2 operators detected a small (approximately 0.2 percent), unexpected, reduced power with simultaneous reduction in reactor coolant system cold leg A temperature, steam generator A pressure, and slight change in core flux azimuthal tilt. The licensee determined that core mass flow was less than required by technical specification 3.2.5 and Unit 2 operators reduced power to approximately 85 percent to restore compliance with the technical specification. The licensee concluded the most likely cause of the reduction in reactor coolant system flow was movement of the cold leg A safety injection system thermal sleeve. The licensee completed an analysis of the condition that allowed returning the unit to 100 percent power. Unit 2 operators raised power to 100 percent power on September 22, 2023, and the unit remained at or near full power for the remainder of the 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
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1 emergency diesel generator (K-4B) during outage of alternate train (K-4A)emergency diesel generator on August 1, 2023
- (2) Unit 1 underground storage/fuel transfer system for emergency diesel generators after system outage and fuel transfer test on August 3, 2023
- (3) Unit 1 125 Vdc vital dc power after charger problem/tripped breaker/degraded batteries on August 10, 2023
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 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 FZ-1030, 1061, and 1062 on July 6, 2023
- (2) Unit 1 computer room FZ-160-B on July 7, 2023
- (3) Unit 2 main steam isolation valve/steampipe room FZ-2155-A on July 11, 2023
- (4) Unit 2 north electrical equipment room FZ-2091-BB on July 12, 2023
- (5) Unit 1 boric acid tank and pump room FZ-120-E on August 1, 2023
- (6) Unit 1 north emergency diesel generator room FZ-86-G on August 31, 2023
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 licensed operator examination failure rates for the requalification annual operating exam administered on June 7, 2023, to July 21, 2023.
- (2) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered from June 19, 2023, to July 28, 2023.
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 on July 7, 2023.
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 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 control room during Unit 2 crew response to degraded reactor coolant system flow and emergent power reduction on September 10, 2023.
- (2) The inspectors observed and evaluated licensed operator performance in the control room during Unit 1 planned downpower to 86 percent and performance of main turbine governor valve testing on September 28, 2023.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (3 Samples)
- (1) The inspectors observed and evaluated Unit 1 requalification job performance measure tasks (transfer control rods to auxiliary power supply, restore power to dead bus) on July 20, 2023.
- (2) The inspectors observed and evaluated Unit 1 training scenario for pressurizer system failure events on August 15, 2023.
- (3) The inspectors observed and evaluated Unit 2 training scenario for overcooling events and excess steam demand on August 22, 2023.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (4 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:
(1)maintenance due to non-functionality of Unit 2 area radiation monitor 2RITS-8905 for equipment hatch area (EITER equipment) on July 27, 2023
- (2) Limitorque operator periodic inspection and lubrication on August 15, 2023 (3)manhole MH-8 mechanical inspection and dewatering on August 17, 2023
- (4) FLEX diesel generator preventive maintenance practices following failure of the K12 diesel generator on November 10, 2021
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 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 1 elevated risk from planned system maintenance on emergency diesel generator B on July 18, 2023
- (2) Unit 2 elevated risk from planned system maintenance on atmospheric dump valve 2CV-0305 at power on July 20, 2023
- (3) Unit 2 elevated risk from planned system maintenance on emergency diesel generator B on July 24, 2023
- (4) Unit 1 elevated risk from planned system maintenance on emergency diesel generator A on August 2, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)operability of Unit 1 emergency feedwater initiation and control system pressure transmitter PT-2667A, installed with a low-pressure vent configuration, unlike the other pressure transmitters in the system, on July 24, 2023 (2)operability of Unit 1 emergency diesel generator 2 after 2-year overhaul on July 27, 2023 (3)operability of Unit 1 primary makeup pump B, P-36B, due to inboard seal leakage on August 30, 2023 (4)operability of Unit 2 reactor coolant system from a step change in reactor coolant flow in loop A due to a rotated or partially ejected high pressure injection thermal sleeve on September 10, 2023
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (6 Samples)
- (1) Unit 1 reactor protection system D control rod drive breaker trip test following maintenance on August 15, 2023
- (2) Unit 1 emergency diesel generator K-4A testing following the 24-month maintenance and air valve replacements on August 17, 2023
- (3) Unit 2 electrohydraulic pump following replacement on September 6, 2023
- (4) Unit 1 vital battery charger D-03A following preventive maintenance on September 18, 2023
- (5) Unit 1 emergency feedwater pump turbine steam generator A admission valve CV-2667 following major preventive maintenance on September 19, 2023
- (6) Unit 1 emergency feedwater pump steam admission valve CV-2663 following major preventive maintenance on September 19, 2023
Surveillance Testing (IP Section 03.01) (4 Samples)
- (1) Unit 2 emergency diesel generator 2K-4B fast start testing on August 24, 2023
- (2) Unit 2 reactor building spray pump P-35B periodic test on September 12, 2023 (3)emergency cooling pond sounding on September 13, 2023
- (4) Unit 2 Red train emergency feedwater suction valves on September 22, 2023
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) Unit 1 service water pump P-4B inservice test on August 8, 2023
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated the maintenance and testing of the alert and notification system between August 31, 2020, and August 19, 2023.
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
- (1) The inspectors evaluated the readiness of the Emergency Preparedness Organization between August 31, 2020, and August 19, 2023. Inspectors also evaluated the licensee's ability to staff their emergency response facilities in accordance with emergency plan commitments.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes:
- Procedure 1903.010, Emergency Action Level Classification, revision 61, with change summary submitted on March 2, 2023
- Arkansas Nuclear One Emergency Plan, revision 48, with change summary submitted on May 11, 2023 In addition, the inspectors evaluated the 10 CFR 50.54(q) emergency plan change process and practices between August 30, 2020, and August 19, 2023. The evaluation reviewed screenings and evaluations documenting implementation of the process. The reviews of the change process documentation or the emergency plan changes do not constitute NRC approval.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the maintenance of the emergency preparedness program between August 30, 2020, and August 19, 2023. The evaluation reviewed evidence of completing various emergency plan commitments, the conduct of drills and exercises, licensee audits and assessments, and the maintenance of equipment important to emergency preparedness. In addition, the inspectors observed an alternate emergency response facilities tabletop drill conducted on August 29, 2023.
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
(1)emergency drill involving Unit 2 loss of coolant accident with fuel failure leading to a General Emergency declaration on September 26,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05)===
- (1) Unit 1 (July 1, 2022, through June 30, 2023)
- (2) Unit 2 (July 1, 2022, through June 30, 2023)
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
- (1) Unit 1 (July 1, 2022, through June 30, 2023)
- (2) Unit 2 (July 1, 2022, through June 30, 2023)
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
- (1) Unit 1 (July 1, 2022, through June 30, 2023)
- (2) Unit 2 (July 1, 2022, through June 30, 2023)
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
- (1) July 1, 2022, through June 30, 2023 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
- (1) July 1, 2022, through June 30, 2023 EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
- (1) July 1, 2022, through June 30, 2023
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) Site challenges to maintaining radiation monitors and repeat instrument failures/obsolescence on August 17, 2023.
The sites corrective action program records and deficiency tagging of radiation monitors shows that keeping the instruments functional is an ongoing struggle. The instruments are obsolete, and it is increasingly difficult to maintain a supply of spare or replacement parts. Repaired instruments do not always continue to operate for a reasonable time and the time burden to site technicians is considerable. The sites plan to address this issue is still years from being implemented.
71153 - Follow Up of Events and Notices of Enforcement Discretion Personnel Performance (IP section 03.03)
- (1) The inspectors evaluated the Unit 2 unplanned downpower to 85 percent for inadequate reactor coolant system flow on September 10,
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
===60854 - Preoperational Testing of an ISFSI Determine by direct observation and independent evaluation whether the licensee had developed, implemented, and evaluated preoperational testing activities to safely load spent fuel from site's spent fuel pool to the Independent Spent Fuel Storage Installation (ISFSI) and safely retrieve spent fuel from the ISFSI and transfer it back to the licensee's spent fuel pool.
Preoperational Testing Of An ISFSI===
- (1) Arkansas Nuclear One (ANO) is a 10 CFR Part 72 general licensee in accordance with 10 CFR 72.210. Previously, the ANO ISFSI consisted of two different cask designs. ANO had loaded 24 canisters of the Energy Solutions ventilated storage cask (VSC) design, VSC-24, (Certificate of Compliance (CoC) No. 72-1007) from 1996 to 2003. Then in 2003, ANO switched to loading the Holtec HI-STORM 100S version C overpacks (CoC 72-1014) containing either a multi-purpose canister (MPC)-24 or MPC-32 containing either 24 or 32 spent fuel assemblies. In 2023, ANO had elected to use the Holtec HI-STORM Flood/Wind (FW) system (CoC 72-1032) to continue storing fuel at the ISFSI. The site's ISFSI pads contained a total of 24 VSC-24 casks, 80 HI-STORM 100 casks and the future casks would be HI-STORM FW casks containing 37 spent fuel assemblies (MPC-37). On August 21-25, 2023, inspectors performed onsite inspections to observe and evaluate the pre-operational testing and training exercises being conducted by the licensee. These operations are described in condition 9 of the CoC and are performed by a general licensee prior to the use of the system to store spent fuel assemblies.
During the inspection period, inspectors specifically observed the following demonstrations that were successfully completed by the licensee:
- movement of the transfer cask from the fuel building to the Cask Transfer Facility using the low profile transporter and rail car
- transition of the transfer cask from the low profile transporter to the Vertical Cask Transporter (VCT)
- removal of the empty transfer cask from the stack-up position.
INSPECTION RESULTS
Unresolved Item (Open)
Use and Acceptance of the Holtec Canister with the CBS Variant Design Change URI 05000313,05000368/2023003-01 60854
Description:
The inspectors identified an unresolved item (URI) related to design changes on the dry cask storage multi-purpose canisters (MPC) utilized by the licensee. On November 6, 2020, Holtec International, the supplier of HI-STORM FW storage system, performed Engineering Change Order (ECO) No. 5018-122 and 72.48 Design No. 1498.
These evaluations performed a design change to introduce a new MPC basket design to the HI-STORM FW dry storage system, designated as the continuous basket shim (CBS) variant.
On September 12, 2023, the NRC issued Inspection Report 07201014/2022-201 (ADAMS Accession No. ML23145A175) to Holtec International, identifying three apparent violations associated with design change. The apparent violations, related to 10 CFR 72.48 and 10 CFR 72.146 requirements, are for Holtecs apparent failures to provide adequate bases that the CBS variant did not require a license amendment, failure to ensure the change did not result in a departure from the method of evaluations described in the Final Safety Analysis Report, and failure to establish design control measures commensurate with those applied to the original design. At this time, the NRC has determined there is no immediate safety concern associated with the use of the modified basket design.
On January 25, 2023, the licensee adopted Holtecs CBS ECO/72.48 through the licensees 72.48 program, LBDCR No. 2022-034, and subsequently loaded the MPC-37-CBS canister during their September 2023 loading campaign.
General licensees are responsible to ensure that each cask they use conforms to the terms, conditions, and specifications of a Certificate of Compliance (CoC) or an amended CoC listed in 72.214 and regulatory requirements in 10 CFR Part 72. Accordingly, pending determination of the final enforcement action to Holtec International associated with the design change, it may be determined that ANO's loading of the dry storage systems did not meet regulatory requirements.
Planned Closure Actions: The licensees performance related to the adoption and use of the MPC-37-CBS canister is unresolved at this time as the NRC has not made a final determination for the apparent violations documented in Inspection Report 07201014/2022-201. The inspectors can evaluate the general licensees compliance with regulatory requirements associated with loading of MPC baskets with the CBS variant once a final determination is made.
Licensee Actions: The licensee entered the issue into its corrective action program and initiated actions to review the results of the NRC's final determination and determine if changes are needed.
Corrective Action References: Condition Report CR-HQN-2023-03197 Failure to Maintain FLEX Equipment Consistent with the Requirements of 10 CFR 50.155(c)(1)
Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000313/2023003-02 Open/Closed
[H.2] - Field Presence 71111.12 The inspectors identified a Green, non-cited violation of 10 CFR 50.155(c)(1), Mitigation of Beyond-Design-Basis Events, when the licensee failed to maintain equipment of sufficient capacity and capability to implement strategies to maintain and restore core cooling, containment, and spent fuel cooling capabilities following a beyond-design-basis external event. Specifically, the licensee failed to implement a fuel oil quality strategy for FLEX diesel-driven equipment, and consequently, FLEX diesel generator K12 failed a surveillance test.
Description:
The site employs various diesel-driven equipment for their Phase 2 FLEX strategies. To maintain adequate quality of the diesel engine fuel oil, annual fluid analysis was required to be completed by Section 5.3.3, FLEX Equipment Maintenance, of Procedure EN-OP-201-01, Arkansas Nuclear One FLEX Program Document, revision 4.
FLEX diesel fuel oil analysis for three parameters (kinematic viscosity, water and sediment, and cloud point) was required by Procedure OP-1000.113, Diesel Fuel Monitoring Program, revision 17. A Model Work Order was developed to perform the periodic sampling and analyses on a 1-year frequency and work orders were issued annually to perform the sampling. The inspectors found that FLEX fuel oil sampling was not being performed.
Instead, the completed work orders stated that fuel oil was replaced in lieu of sampling. No documentation of fuel oil replacement could be found. The documentation that was available indicated the FLEX equipment diesel tanks were initially filled in the 2015-timeframe; and, tanks had not been inspected for water or sediment, fuel oil had not been sampled and analyzed, and tanks had not been drained and refilled with fresh fuel oil.
On November 10, 2021, the K12 800 kW FLEX diesel generator failed its 3-year full load surveillance test and was not capable of fulfilling its mission to power critical loads during a beyond-design-basis event. The licensees equipment failure evaluation (CR-ANO-C-2021-02976 CA-03) documented discovery that every O-ring, seal, washer, and gasket needed reseal, for one of the two fuel oil injection pumps. Debris from the failed fuel oil injection pump clogged the fuel injectors on one side of the engine, preventing its operation at full load.
The evaluation did not document a cause for the failed injection pump (and the inspectors did not find any documentation of cause in the corrective maintenance work order), but it documented that the vendor manual contained a recommendation that inspection, testing, and replacing parts as necessary for the fuel oil injection pump be performed every 4 years.
The licensee had not included this recommendation in the FLEX diesel generator preventive maintenance program. In addition to replacing the fuel oil injection pumps on both the K12 and K11 diesel generators, a corrective action was initiated to add the 4-year, vendor-recommended, fuel oil injection pump preventive maintenance to the preventive maintenance program. Based on the facts that FLEX fuel oil sampling and analysis had not been performed and fuel oil in FLEX equipment was not being periodically replaced, and that diesel fuel oil is expected to degrade over time, the inspectors concluded degraded fuel oil contributed to the failure.
The inspectors reviewed the licensees FLEX diesel generator preventive maintenance requirements with those recommended in the K11/K12 Vendor Manual TDG971 0010, FLEX Portable Diesel Generator, revision 0. Procedure EN-OP-201-01, Arkansas Nuclear One FLEX Program Document, revision 4, identified the following preventive maintenance items and frequencies for the K11/K12 FLEX diesel generators:
Functional Test and Inspection 6 months Operational Inspection, Fluid Analysis 1 year Fluid Filter Replacement 2 years Generator Full Load Test 3 years The vendor manual identified several additional preventive maintenance recommendations and some that were at different frequencies for engines used as emergency engines.
Examples of vendor-recommended preventive maintenance activities that the licensee did not include were: operate the engine weekly at no load; operate the engine monthly at 1/2 load; drain water out of the fuel tank annually; drain water from fuel filters annually; and check fuel injector spray conditions and spray pressure annually.
The licensee believes that technical justifications for deviations from vendor recommendations for preventive maintenance were not required because their FLEX preventive maintenance program implemented the EPRI Templates referenced in Nuclear Energy Institute (NEI) letter dated October 3, 2013, which forwarded EPRI Technical Report 3002000623, Nuclear Maintenance Applications Center: Preventive Maintenance Basis for FLEX Equipment, (ADAMS Accession No. ML13276A573). This was endorsed by the NRC in a letter dated October 7, 2013, (ADAMS Accession No. ML13276A224). The EPRI document described the expansion of EPRIs preventive maintenance basis database to include FLEX equipment and a process for developing preventive maintenance templates for FLEX equipment. The licensee informed the inspectors that the preventive maintenance program for their K11 and K12 FLEX diesel generators (which have Mitsubishi engines) were based on the EPRI template created for FLEX generators (which was based on John Deere engines). The licensee stated that similar expectations exist for normal-use periodic operating requirements for John Deere and Mitsubishi engines, so it was appropriate to use the EPRI templates for the ANO FLEX diesel generators. The licensees position was that they follow the EPRI templates and evaluate any deviations from them; evaluations were not required for deviations from vendor recommendations.
The inspectors reviewed the licensees FLEX preventive maintenance template (based on the EPRI template) for the FLEX Diesel Generators, PM Basis Template EN FLEX Generator - 1000KW or Less - Diesel Driven, revision 0. The inspectors found the licensee had identified and evaluated one deviation from the EPRI template. The licensees PM Basis template said the EPRI template identified a 3-month frequency for the FLEX diesel generator Functional Test and Inspection. However, the licensee stated a 6-month frequency was acceptable because their use of an EPRI PM Database Vulnerability Tool resulted in only a 2 percent increase in failure rate for the extended frequency. The inspectors noted that the licensees FLEX preventive maintenance template also included a note stating, This template is intended to be used in consultation with the specific vendor manuals associated with the specific equipment of interest. Neither the deviation from the template, nor any other location in the template, referenced recommendations from the Mitsubishi vendor manual.
The NRCs October 7, 2013, letter (issued after NRC endorsement of NEI 12-06, revision 0)regarding EPRI templates, only stated that the staff agreed that the EPRI Report and templates provided a useful input to an acceptable approach for licensees to use in developing their maintenance and testing programs. The inspectors noted that NEI has issued revision 4 of NEI 12-06 (ADAMS Accession No. ML16354B421) and it was reviewed and endorsed by the NRC when NRC issued JLD-ISG-2012-01, revision 2, in February 2018 (ADAMS Accession No. ML17005A188). This document, with an effective date of April 25, 2018, represented the most recent NRC guidance and clarification for meeting FLEX requirements. The inspectors reviewed NEI 12-06, revision 4, and noted an important clarification was added in section 11.5 for FLEX maintenance and testing that was not included in revision 0.
Revision 0:
Standard industry templates (e.g., EPRI) and associated bases will be developed to define specific maintenance and testing including the following:
Revision 4:
Standard industry templates (e.g., EPRI) and associated bases (i.e., site-specific)
[emphasis added] will be developed to define specific maintenance and testing including the following:
The text immediately following was the same in both revisions, including statements for periodic testing and frequency and preventive maintenance, that, The basis should be documented and deviations from vendor recommendations and applicable standards should be justified.
The inspectors concluded the addition of site-specific in the language of NEI 12-06, revision 4, provided added emphasis on the need for the licensee to evaluate differences between the generic EPRI templates and site-specific equipment requirements that are needed for different equipment, like Mitsubishi diesel generators.
Corrective Actions: The licensee was not able to repair the K12 engine on site. It was transported to a vendor site in Louisiana where the engine was repaired and returned to the ANO site. The ANO Flex Marshal position was transitioned to a different employee and diesel fuel sampling of the FLEX equipment was initiated in 2023 at a quarterly periodicity until fuel quality was definitively documented and trended.
Corrective Action References: The licensee entered this issue into the sites corrective action program with condition reports CR-ANO-C-2023-03536 and CR-ANO-C-2023-03537.
Performance Assessment:
Performance Deficiency: The failure to maintain equipment reliability for mitigation strategies for beyond-design basis external events was a performance deficiency. Specifically, the licensee failed to perform fuel oil sampling and analysis to maintain fuel oil quality for FLEX diesel-driven equipment which contributed to the failure of FLEX diesel generator K12.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to implement a fuel oil quality strategy for FLEX diesel-driven equipment, and consequently, FLEX diesel generator K12 failed a surveillance test and was not functional for almost 3 months.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using the Mitigating Systems exhibit 2, section E, for FLEX findings, the inspectors determined that the issue finding screened as Green because:
1. it was not associated with equipment, training, procedures, and/or other programmatic
aspects credited for the sole purpose of satisfying the requirements of Order EA-12-051 or 10 CFR 50.155 for spent fuel pool instrumentation or EA-13-109 for containment venting; and,
2. it did not involve equipment, training, procedures, and/or other programmatic aspects
credited in any Phase 1 or 2 FLEX strategy such that any FLEX function (such as extended high-pressure coolant injection/reactor core isolation cooling/auxiliary feedwater operation, providing FLEX dc power, FLEX ac power, or FLEX reactor coolant system feed) could not be completed in accordance with existing plant procedures within the time allotted for an exposure period of greater than 21 days.
Specifically, the licensee failed to implement a fuel oil quality strategy for FLEX diesel-driven equipment, where the licensee failed to perform fuel oil analysis at the specified annual frequency, and consequently, FLEX diesel generator K12 failed testing and was unavailable for almost 3 months. However, the FLEX ac power function could have been completed because the backup piece of equipment (the K11 FLEX portable diesel generator) remained available and could have been used within the time allotted.
Cross-Cutting Aspect: H.2 - Field Presence: Leaders are commonly seen in the work areas of the plant observing, coaching, and reinforcing standards and expectations. Deviations from standards and expectations are corrected promptly. Senior managers ensure supervisory and management oversight of work activities, including contractors and supplemental personnel.
Specifically, although the FLEX program was an Entergy fleet program, the ANO operations department was responsible for implementing the FLEX equipment testing and maintenance at the ANO site. Inadequate training was given to the ANO FLEX Marshal and little, if any, direct supervisory oversight occurred.
Enforcement:
Violation: NRC regulation 10 CFR 50.155(c)(1) states, The equipment relied on for the mitigation strategies and guidelines required by paragraph (b)(1) of this section must have sufficient capacity and capability to perform the functions required by paragraph (b)(1) of this section. Paragraph (b)(1) states, in part, that strategies and guidelines must include the following:
- (i) Maintaining or restoring core cooling, containment, and spent fuel pool cooling capabilities The licensee describes its strategies to meet 10 CFR 50.155(b)(1) and (c)(1) in Procedure EN-OP-201-01, Arkansas Nuclear One FLEX Program Document, revision 4, which required annual analysis of FLEX fuel in accordance with Procedure OP-1000.113, Diesel Fuel Monitoring Program, revision 17.
Contrary to the above, since 2015, the licensee failed to implement the annual sampling and analysis requirements for FLEX diesel fuel in accordance with procedures EN-OP-201-01 and OP-1000.113.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
Failure to Conduct Drills in Accordance with the Site Emergency Plan Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000313,05000368/2023003-03 Open/Closed
[H.13] -
Consistent Process 71114.05 The inspectors identified a Green, non-cited violation of 10 CFR 50.54(q)(2) associated with the licensees failure to follow their emergency plan. Specifically, the licensee failed to follow Arkansas Nuclear One Emergency Plan, revisions 46 and 47, section N.2.4, which requires annual radiological monitoring drills. The licensee failed to conduct correctly scoped radiological monitoring drills in 2021 and 2022 by not including sampling activities both onsite and offsite.
Description:
The inspectors reviewed drills and exercises conducted by the licensee between 2020 and 2022 and compared the drill and exercise evaluation reports to the requirements of the licensee emergency plan.
Arkansas Nuclear One Emergency Plan, revisions 46 and 47, section N.2.4, requires that plant environs and radiological monitoring drills (on and offsite) are conducted annually. To verify these took place, the inspectors evaluated radiological monitoring drill reports (environmental drills) held on August 6, 2020, June 3, 2021, and June 1, 2022. In reviewing the reports, the inspectors observed that the sampling locations were denoted with alpha-numeric codes, so further questions were asked about where they were located with respect to the site boundary. Discussion with the licensee staff revealed that sampling activities in 2020 took place appropriately both onsite and offsite, but in 2021 and 2022 the samples were only evaluated at offsite locations.
The inspectors reviewed the licensees documentation describing how emergency preparedness drills were developed and implemented. To ensure that the drill included necessary aspects of scope in design, the licensee modified Performance Objective I.9, Environmental Phase Monitoring, taken from Procedure EN-EP-306, Drills and Exercises, attachment 6, to include more specific language. It was revised to say, Demonstrate the ability to monitor post-plume environmental conditions in the field (at least one sample onsite and one offsite). This performance objective was used effectively in 2020 to ensure that the drill scope included sampling activities onsite and offsite, as well as to conduct the drill correctly. In 2021, the radiological monitoring drill used the same performance objective in design, but the licensee failed to use it to ensure appropriate implementation. In 2022, after some changes to drill documentation format, the performance objective statement was revised, removing text reinforcing the need for onsite and offsite sampling, introducing an error in drill design.
The inspectors determined that the licensee did not conduct annual radiological monitoring drills in a manner that ensured that all sampling activities were evaluated in all specified locations. Therefore, the inspectors concluded that the licensee did not follow the requirements of the site emergency plan.
Corrective Actions: The licensee entered these issues into the corrective action program.
Corrective Action References: Condition Report CR-ANO-C-2023-03166
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to conduct drills required by the emergency plan is a performance deficiency within the licensees ability to foresee and correct.
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 take adequate measures to protect the health and safety of the public is degraded when the licensee does not perform drills and exercises to ensure emergency response organization proficiency.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix B, Emergency Preparedness SDP. Using attachment 2, 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. The planning standard function was not lost because the licensee did conduct drills, training, and normal sampling activities that addressed portions of the related emergency plan commitments.
Cross-Cutting Aspect: H.13 - Consistent Process: Individuals use a consistent, systematic approach to make decisions. The licensee did not use a consistent, systematic approach to making decisions regarding use of radiological monitoring drills performance objectives.
Specifically, the associated drill performance objectives were not used regularly to ensure that drills as implemented included the appropriate scope elements in the evaluation. This would have provided assurance that the emergency plan commitments would be addressed in a regular fashion.
Enforcement:
Violation: Title 10 CFR 50.54(q)(2) requires, in part, that a power reactor licensee follow an emergency plan which meets the requirements of appendix E to 10 CFR Part 50 and the standards of 10 CFR 50.47(b). Planning standard 10 CFR 50.47(b)(14) requires, in part, that the licensee conduct periodic drills to maintain key skills. Arkansas Nuclear One Emergency Plan, revisions 46 and 47, section N.2.4, states, in part, that plant environs and radiological monitoring drills (on and offsite) are conducted annually.
Contrary to the above, between January 1, 2022, and September 1, 2023, Arkansas Nuclear One failed to follow an emergency plan which met the requirements of appendix E and the standards of 10 CFR 50.47(b). Specifically, the licensee failed to conduct annual radiological monitoring drills including sampling activity evaluation both on and offsite in 2021 and 2022, which are required by the emergency plan to maintain key emergency response organization skills.
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 July 13, 2023, the inspectors presented the ANO-1 2023 biennial requalification inspection results to Albert Fields, Training Supervisor, and other members of the licensee staff.
- On September 1, 2023, the inspectors presented the emergency preparedness program inspection results to Frank Shewmake, Operations Director, and other members of the licensee staff.
- On October 19, 2023, the inspectors presented the ANO independent spent fuel storage installation dry run operations inspection results to Brian Patrick, Regulatory Assurance and Performance Improvement Director, and other members of the licensee staff.
- On October 19, 2023, the inspectors presented the integrated inspection results to Brian Patrick, Regulatory Assurance and Performance Improvement Director, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
60854
Corrective Action
Documents
Holtec MPC-CBS Variant
60854
Procedures
Procedure 3407.003
HI-STORM FW Loading Operations
60854
Procedures
Procedure 3407.005
HI-STORM FW Transfer and Transport Operations
Corrective Action
Documents
CR-ANO-
1-2022-00794, 1-2022-00883, 1-2023-00164, 1-2023-
00453, 1-2023-00492, 1-2023-00499, 1-2023-00790, 1-
23-00791, 1-2023-01339, C-2022-003531, C-2023-
2882
Procedures
OP-1104.036
Emergency Diesel Generator Operation
Procedures
OP-1412.081
Battery Chargers Cleaning and Inspection
Procedures
OP-1412.216
Vital 120 VAC 10 KVA Inverter Inspection
Procedures
ULD-1-SYS-03
Unit 1 125 Volt DC System
Work Orders
Corrective Action
Documents
CR-ANO-
1-2022-01281, 1-2022-01651, 1-2022-03111, 1-2023-
00794, 1-2023-01915, C-2021-00858, C-2023-01341,
Engineering
Changes
EC Reply to Point to Documentation Stating Fire Wrap is
not Required in Correlation with EC-85804
Miscellaneous
Unit 1 and Unit 2 Fire Hazards Analysis
Miscellaneous
Unit 1 Prefire Plans
Miscellaneous
Unit 2 Prefire Plans
Procedures
OP-1003.005
Fire Prevention Inspection
Procedures
ANO Prefire Plan (Unit 1)
Procedures
ANO Prefire Plan (Unit 2)
Corrective Action
Documents
CR-ANO-1-2021-
2574
Condition Report (Exam Security)
08/10/2021
Corrective Action
Documents
CR-ANO-1-2022-
00513
NI Calibration PU&A
03/23/2022
Corrective Action
Documents
CR-ANO-1-2023-
00857
Operations Training Staffing
06/15/2023
Corrective Action
Documents
CR-ANO-C-2021-
2533
Exam Security
09/27/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-ANO-C-2022-
00407
Condition Report (Exam Security)
2/11/2022
Corrective Action
Documents
CR-ANO-C-2022-
251
Condition Report (Exam Security)
05/05/2022
Corrective Action
Documents
CR-ANO-C-2022-
01881
Operator Qualification Requirements
07/11/2022
Corrective Action
Documents
CR-ANO-C-2023-
294
Condition Report (Exam Security)
01/31/2023
Corrective Action
Documents
CR-ANO-C-2023-
01375
NRC Medical Reporting
05/09/2023
Corrective Action
Documents
DR-21-0051
Simulator Discrepancy Report
09/02/2021
Corrective Action
Documents
DR-22-0034
Simulator Discrepancy Report
11/17/2022
Corrective Action
Documents
DR-23-0011
Simulator Discrepancy Report
04/20/2023
Corrective Action
Documents
EN-FAP-OM-029 Rev
Adverse Condition
Monitoring and
Contingency Plan
Maintaining Condenser Vacuum while P-3B and P-3D
are OOS
06/01/2023,
Rev 2
Corrective Action
Documents
EN-FAP-OM-029 Rev
Adverse Condition
Monitoring and
Contingency Plan
Elevated Main Generator Hydrogen Leakage
03/20/2023,
Rev 5
Corrective Action
Documents
EN-FAP-OM-029 Rev
Adverse Condition
Monitoring and
Contingency Plan
Elevated Exciter Air Cooler Temperatures
07/03/2023,
Rev 0
Corrective Action
Documents
TQF-201-IM05
Cycle 2201 Simulator Evaluation Remediation
09/07/2021,
Rev 0
Corrective Action
Documents
WT-WTANO-2021-
00014
Operator Diagnosis - Plant Event
09/07/2021
Corrective Action
Documents
WT-WTANO-2021-
270
LOR Performance Issue - RB CLG Actions
09/13/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
ANO1 Modifications Not Completed Last Two Years
(none)
06/09/2023
Miscellaneous
ANO1 Simulator Open Work Items 6-9-23
06/09/2023
Miscellaneous
JPM Overlap
Miscellaneous
ANO-1 Simulator Core Reload Acceptance Test - Cycle
Miscellaneous
Cycle 22 and 23 Training Attendance Records
Miscellaneous
23 Annual Operating Test - Week 2
Miscellaneous
23 Annual Operating Test - Week 4
Miscellaneous
Perform Starting the Emergency Diesel Without DC
Control Power
Miscellaneous
Reset NNI-Y Power Supply
Miscellaneous
Unit 1 Cycle 31 Simulator Operability Test
Miscellaneous
A1WEXLORBIENNIAL
2305 RO Week 3
RO Week 3 Written Examination
Miscellaneous
A1WEXLORBIENNIAL
2305 SRO Week 3
SRO Week 3 Written Examination
Miscellaneous
eSOMS Report -
Watchstanding
Records
Watchstanding Records Crew B
06/08/2023
Miscellaneous
Licensed Operator
Medical Records
Six licensed operator medical records
N/A
Miscellaneous
SES-1-016
ANO1 Dynamic Exam Scenario
Miscellaneous
SES-1-032
ANO1 Dynamic Exam Scenario
Procedures
1063.008
Operations Training Sequence
Procedures
ASREC-OPS-FHSRO
Activation of SRO License for Fuel Handling Activities
Procedures
ASREC-OPS-LICRA
Activation of RO License
Procedures
DG-TRNA-015-
EXAMSEC
Simulator Exam Security Guidelines
Procedures
EN-OP-115-06
Activation and Deactivation of Licenses, and Maintaining
Active License Status
Procedures
Conduct of Simulator Training
Procedures
Licensed Operator Requalification Annual and Biennial
Exam Development
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
TQF-210-DD04
RO/SRO Performance Evaluation Report
Procedures
TQF-210-DD04-Grade
RO/SRO Performance Evaluation Grading Criteria
Corrective Action
Documents
CR-ANO-
1-2019-01821, 1-2019-04374, 1-2021-01867, 2-2023-
2453, 2-2023-02457
Miscellaneous
Appendix A, Technical Specifications to Facility
Operating License
Procedures
RCS Overcooling Technical Guidelines
Procedures
Overcooling Event in Modes 1 or 2 Technical Guidelines
Procedures
OP-1102.004
Power Operation
Procedures
OP-1103.004
Soluble Poison Concentration Control
Procedures
OP-1103.005
Pressurizer Operations
Procedures
OP-1103.013
RCS Leak Detection
Procedures
OP-1106.009
Turbine Startup
Procedures
OP-1107.002
ES Electrical System Operation
Procedures
OP-1203.015
Pressurizer Systems Failures
Procedures
OP-2102.004
Power Operation
Procedures
OP-2103.018
RCS Flow Rate Calculation
Procedures
OP-2203.025
RCP Emergencies
Procedures
OP-2203.050
Overcooling Event in Modes 1 or 2
Work Orders
WO 53030817, 53030820
Corrective Action
Documents
CR-HQN-2020-00226, WT-WTANO-2022-00058, WT-
Corrective Action
Documents
CR-ANO-
2-2022-01408, 2-2023-00108, 2-2023-00859, 2-2023-
01808, C-2021-02976, C-2021-02985, C-2022-00269,
C-2022-00376, C-2022-00538, C-2022-00890, C-2022-
225, C-2022-01388, C-2022-01397, C-2023-00036,
C-2023-00387, C-2023-03536, C-2023-03537,
Miscellaneous
PM Basis Template EN FLEX Generator - 1000KW or
Less - Diesel Driven
11/21/2014
Miscellaneous
2016-00051
FLEX Oil PM Sampling Parameters & Acceptance
Criteria Position Paper
03/28/2016
Miscellaneous
EMRG36864
Operators Manual - 9.0 L OEM Diesel Engines
03/06/2013
Miscellaneous
IDLC8000-2M
Generac Industrial Diesel Generator
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
IPH1250/175DJ
High Performance Industrial Pumping Module
11/2014
Miscellaneous
MWO 00298463-01
Manhole MH-8, Mechanical: Inspection and Dewatering
03/10/2022
Miscellaneous
TDG971 0010
FLEX Portable Diesel Generator
Procedures
CFSG-005
Initial Assessment and FLEX Equipment Staging
Procedures
Equipment Important to Emergency Response
Procedures
Limitorque Valve Operator Model SMB/SB/SBD-000
Through 5 MOV and HBC Periodic Inspection
Procedures
Diverse and Flexible Coping Strategies (FLEX) Fleet
Program Document
Procedures
EN-OP-201-01
Arkansas Nuclear One FLEX Program Document
Procedures
OP-1000.113
Diesel Fuel Monitoring Program
Procedures
OP-1903.010
Emergency Action Level Classification
Procedures
OP-2105.016
Radiation Monitoring and Evacuation System
Procedures
OP-2404.018
U2 Containment Area Rad Mon Sys Cal
Work Orders
WO 2929822, 52971630
Corrective Action
Documents
CR-ANO-
2-2020-01970, 2-2020-03874, 2-2021-00251, 2-2022-
2139, C-2023-02904
Procedures
COPD-024
Risk Assessment Guidelines
Procedures
On Line Risk Assessment
Procedures
OP-1104.036
Emergency Diesel Generator Operation
Procedures
OP-1107.001
Electrical Systems Operations
135
Procedures
OP-2104.036
Emergency Diesel Generator Operations
104
Procedures
OP-2104.037
Alternate AC Generator Operations
Procedures
OP-2105.008
Steam Dump and Bypass Control System Operations
Procedures
OP-2107.001
Electrical Systems Operations
138
Work Orders
WO 2988793, 53012021
Calculations
CALC-07-R-1002-01
ECCS Leakage Quantities to the Auxiliary Building
Calculations
CALC-89-E-0039-02
HPI Seal Integrity Evaluation
Corrective Action
Documents
CR-ANO-
1-2022-02669, 1-2022-02739, 1-2023-00378, 1-2023-
00896, 1-2023-01190, 2-2023-2457, 2-2018-2976, 2-
2013-1190
Drawings
M-2210, Sheet 1
Piping and Instrument Diagram Service Water System
Engineering
0054051358
RCS Flow Margin Improvement
09/20/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Changes
Engineering
Changes
29844
Unit 2 Service Water Loop 2 Suction Supply to 2P-7A
Leak
08/11/2023
Engineering
Changes
54036605
Operability Input Regarding CR-ANO-2-2023-02299
Service Water Leak Near Loop 2 Supply Header Drain
Valve 2SW-1551"
08/12/2023
Miscellaneous
ASME Boiler and
Pressure Vessel
Code, Code Case N-
513-4
Evaluation Criteria for Temporary Acceptance of Flaws
in Moderate Energy Class 2 or 3 Piping,Section XI,
Division 1
05/07/2014
Miscellaneous
STM 1-04
Primary Makeup and Purification
Miscellaneous
ULD-1-SYS-02
ANO-1 Makeup and Purification/High Pressure Injection
System
NDE Reports
Report No.: 2-BOP-
UT-23-024
Component ID: 2SW-1551, U2-327 Squeeze Pit.
08/12/2023
NDE Reports
Report No.: 2-BOP-
VE-20-001
Component ID: A SI Nozzle Thermal Sleeve, A SI
Nozzle Thermal Sleeve Detection
03/27/2020
NDE Reports
Report No.: 2-BOP-
VE-20-002
Component ID: C SI Nozzle Thermal Sleeve, C SI
Nozzle Thermal Sleeve Detection
03/27/2020
NDE Reports
Report No.: 2-BOP-
VE-20-003
Component ID: D SI Nozzle Thermal Sleeve, D SI
Nozzle Thermal Sleeve Detection
03/27/2023
NDE Reports
Report No.: 2-BOP-
VE-20-003
Component ID: C SI Nozzle Thermal Sleeve, C SI
Nozzle Thermal Sleeve Detection
04/21/2023
NDE Reports
Report No.: 2-BOP-
VE-20-004
Component ID: D SI Nozzle Thermal Sleeve, D SI
Nozzle Thermal Sleeve Detection
04/21/2023
NDE Reports
Report No.: 2-BOP-
VE-20-004
Component ID: B Safety Injection, B Safety
Inspection
03/30/2020
NDE Reports
Report No.: 2-BOP-
VE-21-001
Component ID: A SI Nozzle Thermal Sleeve, A SI
Nozzle Thermal Sleeve Detection
09/29/2021
NDE Reports
Report No.: 2-BOP-
VE-21-005
Component ID: D SI Nozzle Thermal Sleeve, D SI
Nozzle Thermal Sleeve Detection
10/08/2021
NDE Reports
Report No.: 2-BOP-
VE-23-002
Component ID: A SI Nozzle Thermal Sleeve, A SI
Nozzle Thermal Sleeve Detection
04/21/2023
NDE Reports
Report No.: 2-BOP-
Component ID: 2HBC-86-6 Pipe, U2 335 North Hallway
08/11/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
VE-23-008
NDE Reports
Report No.: 2-BOP-
VE-23-009
Component ID: 2SW-1551, U2-327 Squeeze Pit.
08/12/2023
Procedures
Corrective Action Program
Procedures
Operability Determination Process
Procedures
OP-1104.036
Emergency Diesel Generator Operation
Procedures
OP-1304.098
Unit 1 EFIC Channel A Calibration
Procedures
OP-1304.135
Unit 1 Emergency Diesel Generator K-4B Instrument
Calibration
Procedures
OP-1305.003
M/U & Purification Sys. Integrity Test & Leak Rate
Determination
Procedures
Report No.: 2-BOP-
VE-21-004
Component ID: C SI Nozzle Thermal Sleeve, C SI
Nozzle Thermal Sleeve Detection
10/08/2021
Work Orders
WO 2990667, 52997083
Calculations
CALC-91-E-0099-13
ECP Hydrographic Survey
Corrective Action
Documents
1-2022-00883, 1-2022-02658, 2-2022-00423, 2-2022-
01383, 2-2023-01393, 2-2023-02352, 2-2023-02424, 2-
23-02439, C-2021-01589, C-2022-02560, C-2023-
289, C-2023-03344, 1-2023-1309, 1-2023-1310,
Engineering
Changes
2CV-1036-2 Control Wiring Modification
Engineering
Changes
2CV-0716-1 Acceptable Normal Range and Limiting
Value Stroke Time Limits for Open Stroke Time to be
Used in OP-2106-006 Supplement 3A
Engineering
Changes
P-4B Service Water Acceptance Criteria Rebaseline per
Miscellaneous
Unit 1 Station Log
08/03/2023
Miscellaneous
ANO Performance Indicator Report for 4Q22
01/18/2023
Miscellaneous
ULD-1-SYS-03
Unit 1 125 Volt DC System
Miscellaneous
ULD-2-SYS-12
ANO U2 Emergency Feedwater System
Procedures
Limitorque Valve Operator Model SMB/SB/SBD-000
Through 5 MOV and HBC Periodic Inspection
Procedures
OP-1104.005
Unit 2 Reactor Building Spray System Operation
Procedures
OP-1104.029
Service Water and Auxiliary Cooling System
27
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
OP-1104.036
Emergency Diesel Generator Operation
Procedures
OP-1107.004
Battery and 125 VDC Distribution
Procedures
OP-1304.128
Unit 1 RPS-D/CRD Breaker Trip Test
Procedures
OP-1306.019
Annual Emergency Cooling Pond Sounding
Procedures
OP-1402.066
24-month inspection of Unit One Emergency Diesel
Generator Engine
Procedures
OP-2104.036
Emergency Diesel Generator Operations
104
Procedures
OP-2104.037
Alternate AC Diesel Generator Operations
Procedures
OP-2106.006
Emergency Feedwater System Operations
110
Procedures
OP-2106.012
Electrohydraulic Oil System Operation
Work Orders
WO 569303, 52996055, 53004058, 53009255, 53029292,
53029670, 53036465, 53037178, 53037312, 54027672,
54033183, 54039748, 54048783, 52995597, 52996095,
53038477
Corrective Action
Documents
CR-ANO-
C-2021-00978, C-2023-01794
Miscellaneous
Letter of Agreement Between Entergy Operations, Inc.,
and Radio Station KXRJ
2/14/2022
Miscellaneous
KLD TR-1208
Arkansas Nuclear One Alert and Notification System
(ANS) Design Report
2/14/2020
Procedures
ANO Emergency Planning Desk Guide - Early Warning
System
Corrective Action
Documents
CR-ANO-
C-2023-01762, C-2023-01763
Corrective Action
Documents
Resulting from
Inspection
CR-ANO-
C-2023-03114
Miscellaneous
Form 1903.062C
Emergency Response Staffing Drill - March 10, 2022
03/28/2022
Miscellaneous
Form 1903.062C
Emergency Response Staffing Drill - February 10, 2021
2/11/2021
Miscellaneous
Form 1903.062C
Emergency Response Staffing Drill - June 25, 2022
06/28/2022
Miscellaneous
Form 1903.062C
Emergency Response Staffing Drill - June 19, 2021
06/22/2021
Miscellaneous
Form 1903.062C
Emergency Response Staffing Drill - September 21,
22
09/22/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Form 1903.062C
Emergency Response Staffing Drill - September 23,
21
09/28/2021
Miscellaneous
Form 1903.062C
Emergency Response Staffing Drill - December 4, 2020
2/10/2020
Miscellaneous
Form 1903.062C
Emergency Response Staffing Drill - December 16, 2021
2/21/2021
Miscellaneous
Form 1903.062C
Emergency Response Staffing Drill - March 21, 2023
03/21/2023
Miscellaneous
Form 1903.062C
Emergency Response Staffing Drill - June 25, 2023
06/26/2023
Miscellaneous
Form 1903.062C
Emergency Response Staffing Drill - December 19, 2022
2/19/2022
Procedures
1903.062
Communications System Operating Procedure
Procedures
1903.080
Emergency Operations Facility (EOF) Activation
Procedures
Emergency Response Organization Notification System
Corrective Action
Documents
CR-ANO-
1-2018-04843, 1-2020-01781
Miscellaneous
CFR 50.54(q) Screening, Procedure/Document
Number: EPLAN; Revision: 048; Title: ANO Emergency
Plan
04/07/2023
Miscellaneous
CFR 50.54(q) Evaluation, Procedure/Document
Number: EPLAN; Revision: 048; Title: ANO Emergency
Plan
04/07/2023
Miscellaneous
CFR 50.54(q) Screening, Procedure/Document
Number: OP-1903.010; Revision: 060; Title: Emergency
Action Level Classification
05/24/2022
Miscellaneous
CFR 50.54(q) Screening, Procedure/Document
Number: ANO Emergency Plan; Revision: 46; Title: ANO
2/18/2021
Miscellaneous
CFR 50.54(q)(3) Evaluation, Procedure/Document
Number: OP-1903.010; Revision: 060; Title: Emergency
Action Level Classification
05/04/2022
Miscellaneous
CFR 50.54(q)(3) Evaluation, Procedure/Document
Number: ANO Emergency Plan; Revision: 46; Title: ANO
2/08/2021
Miscellaneous
CFR 50.54(q)(2) Review, Procedure/Document
Number: OP-1903.053; Revision: 009; Title: Logistical
Support
01/27/2021
Miscellaneous
CFR 50.54(q)(3) Evaluation, Procedure/Document
11/29/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Number: EN-EP-801; Revision: 018; Title: Emergency
Response Organization
Miscellaneous
CFR 50.54(q) Screening, Procedure/Document
Number: 1903.010/1903.010-U1 Wall Chart; Revision:
061/001; Title: Emergency Action Level Classification
01/18/2023
Miscellaneous
CFR 50.54(q)(3) Evaluation, Procedure/Document
Number: 1903.010 & 1903.010 U1 WC; Revision: 061 &
001; Title: Emergency Action Level Classifications & Unit
Wall Chart
01/18/2023
Miscellaneous
0CAN032301
Emergency Plan Implementing Procedure Revision;
Arkansas Nuclear One - Units 1 and 2; Docket Nos. 50-
313, 50-368, and 72-13; Renewed Operating Facility
03/02/2023
Miscellaneous
0CAN052302
Arkansas Nuclear One (ANO) Emergency Plan Rev. 48;
Arkansas Nuclear One - Units 1 and 2; NRC Docket
Nos. 50-313 and 50-368; Renewed Facility Operating
05/11/2023
Miscellaneous
1CNA122203
Arkansas Nuclear One, Unit 1 - Issuance of Amendment
No. 278; RE: Revision to Technical Specifications 3.4.12
and 3.4.13 Based on Revised Dose Calculations (EPID
2/09/2022
Procedures
Emergency Planning 10CFR50.54(q) Review Program
Procedures
OP-1903.010
Emergency Action Level Classification
59, 60, 61
Corrective Action
Documents
CR-ANO-
1-2021-00341, 1-2021-03102, 1-2022-01040, 1-2022-
01068, 1-2022-02978, 1-2023-00172, 1-2023-00183, 1-
23-00221, 1-2023-00273, 1-2023-00383, 1-2023-
00410, 1-2023-01045, 2-2022-00042, 2-2022-01132, 2-
23-00245, 2-2023-01937, 2-2023-02189, 2-2023-
250, C-2021-02305, C-2022-01881, C-2022-02072,
C-2022-02272, C-2022-02351, C-2022-02492, C-2022-
2505, C-2022-03107, C-2023-00964
Corrective Action
Documents
CR-ANO-
C-2023-03166, C-2023-03168, C-2023-03178
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Resulting from
Inspection
Miscellaneous
ETE Update State and Local Agreement
03/20/2023
Miscellaneous
23TTD3 Blue Team Tabletop Drill, Entergy Corporation,
Arkansas Nuclear One, 8/29/23
08/29/2023
Miscellaneous
Arkansas Nuclear One (ANO) HP/RP Environmental Drill
Report, 08/06/2020
09/08/2020
Miscellaneous
Arkansas Nuclear One HP/Post Accident Drill Report,
08/04/2020
09/08/2020
Miscellaneous
Arkansas Nuclear One (ANO) Onsite Medical Drill
Report, 10/13/2020
10/26/2020
Miscellaneous
ANO (Arkansas Nuclear One) ERO Green Team Site
Drill Report, 11/11/2020
2/03/2020
Miscellaneous
23 ANO Health Physics - In Plant Monitoring (First
Half), Entergy Corporation, Arkansas Nuclear One,
06/07/2023
06/19/2023
Miscellaneous
ANO 2023 Red Team 2nd Quarter PI Drill, Entergy
Corporation, Arkansas Nuclear One, 06/22/2023
06/28/2023
Miscellaneous
EOF 4th Quarter - PI Drill Green Team, Entergy
Corporation, Arkansas Nuclear One, 12/16/2021
01/06/2022
Miscellaneous
Arkansas Nuclear One (ANO) 10 CFR 50.54(h)(h)(2)
Drill Report, 03/31/2021
04/20/2021
Miscellaneous
Arkansas Nuclear One (ANO) HP/RP Environmental Drill
Report, 06/03/2021
06/24/2021
Miscellaneous
Arkansas Nuclear One HP/Post Accident Drill Report,
03/09/2021
04/07/2021
Miscellaneous
Onsite Medical Drill/HP Drill 12-6-2021, Entergy
Corporation, Arkansas Nuclear One, 12/06/2021
03/10/2022
Miscellaneous
ANO 2022 Environmental (Radiological Monitoring),
Entergy Corporation, Arkansas Nuclear One, 06/01/2022
06/28/2022
Miscellaneous
ANO 2022 Health Physics - In Plant Monitoring (First
Half), Entergy Corporation, Arkansas Nuclear One,
06/16/2022
06/29/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
ANO 2022 Health Physics - In Plant Monitoring (Second
Half), Entergy Corporation, Arkansas Nuclear One,
2/06/2022
2/13/2022
Miscellaneous
Onsite Medical Drill 12/6/2022, Entergy Corporation,
Arkansas Nuclear One, 12/06/2022
05/04/2023
Miscellaneous
ANO 2022 Post Accident Sampling Drill, Entergy
Corporation, Arkansas Nuclear One, 12/08/2022
01/04/2023
Miscellaneous
CNRO2022-00016
Evacuation Time Estimate Reports
09/12/2022
Miscellaneous
Control Room Emergency Response Facility
Walkthrough, March 20, 2021
03/29/2021
Miscellaneous
EOF Emergency Response Facility Walkthrough, March
16, 2022
03/18/2022
Miscellaneous
JIC Emergency Response Facility Walkthrough,
February 9, 2023
2/13/2023
Miscellaneous
1903.004-G Annual EAL Review
2/14/2021
Miscellaneous
Form 1903.004-M
ETE Update
04/02/2023
Miscellaneous
KLD TR-1167
Arkansas Nuclear One 2020 Population Update Analysis
09/19/2020
Miscellaneous
NQ-2021-007
QA Audit Report QA-07-2021-ANO-1, 2021 QA Audit of
Emergency Preparedness at Arkansas Nuclear One
(ANO)
05/06/2021
Miscellaneous
NQ-2023-008
QA Audit Report QA-7-2023-ANO-1, 2023 QA Audit of
Emergency Preparedness Programs at Arkansas
Nuclear One (ANO)
05/11/2023
Miscellaneous
QS-2022-ANO-002
Quality Assurance Surveillance Report, Activity: 2022
Emergency Preparedness Surveillance, Dates: 3/28/22
to 4/4/22
04/04/2022
Procedures
1903.062
Communications System Operating Procedure
Procedures
1903.069
Equipment Important to Emergency Response
9, 10
Procedures
1904.002
Offsite Dose Projections
Procedures
Equipment Important to Emergency Response (EITER)
Procedures
EN-EP-202-01
Procedures
Drills and Exercises
Procedures
Declared Emergency Recovery and Re-entry
Procedures
Technical Support Center (TSC) Operations
7, 8
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
EN-FAP-EP-005
Emergency Preparedness Performance Indicators
13-17
Procedures
EN-FAP-LI-001
Performance Improvement Review Group (PRG)
Process
Procedures
Corrective Action Program
Procedures
Tending and Performance Review Process
Procedures
Audit Process
Procedures
OP-1903.004
Admin. & Maintenance of Emergency Plan &
Implementing Procedures
Procedures
OP-1903.080
Emergency Operations Facility (EOF) Activation
Work Orders
Work Order Number
535066, 566529, 581716, 582258, 591346, 596438,
54030331
Procedures
OP-1903.010
Emergency Action Level Classification
Procedures
OP-1903.011
Emergency Response/Notifications
Procedures
OP-2203.024
Loss of Turbine Load
71151
Corrective Action
Documents
CR-ANO-
C-2022-03406, C-2023-00782, C-2023-00779
71151
Miscellaneous
Blue Team EOF PI Drill, Entergy Corporation, Arkansas
Nuclear One, 09/01/2022
09/14/2022
71151
Miscellaneous
Red Team EOF PI Drill, Entergy Corporation, Arkansas
Nuclear One, 12/01/2022
2/12/2022
71151
Miscellaneous
Blue Team EOF PI Drill, Entergy Corporation, Arkansas
Nuclear One, 12/06/2022
2/12/2022
71151
Miscellaneous
23 ANO 23FSD1 Green Team, Entergy Corporation,
Arkansas Nuclear One, 03/07/2023
04/06/2023
71151
Miscellaneous
23 ANO 23FSD2 Yellow Team, Entergy Corporation,
Arkansas Nuclear One, 06/06/2023
06/26/2023
71151
Miscellaneous
ANO Performance Indicator Report for 3Q22
10/12/2022
71151
Miscellaneous
ANO Performance Indicator Report for 1Q23
04/20/2023
71151
Miscellaneous
ANO Performance Indicator Report for 2Q23
07/18/2023
71151
Procedures
Emergency Response Organization
71151
Procedures
EN-FAP-EP-005
Emergency Preparedness Performance Indicators
71151
Procedures
Regulatory Performance Indicator Process
17-21
71151
Procedures
Emergency Planning Performance Indicators
5, 6, 7
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-ANO-
C-2023-03025
Corrective Action
Documents
CR-ANO-
2-2023-02453, 2-2023-02457
Procedures
OP-2102.004
Power Operation
Procedures
OP-2103.018
RCS Flow Rate Calculation
Procedures
OP-2203.025
RCP Emergencies
21