IR 05000313/2024003
| ML24313A031 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/12/2024 |
| From: | John Dixon NRC/RGN-IV/DORS/PBD |
| To: | Pehrson D Entergy Operations |
| References | |
| IR 2024003 | |
| Download: ML24313A031 (1) | |
Text
November 12, 2024
SUBJECT:
ARKANSAS NUCLEAR ONE - INTEGRATED INSPECTION REPORT 05000313/2024003 AND 05000368/2024003
Dear Doug Pehrson:
On September 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Arkansas Nuclear One. On October 18, 2024, 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.
Four findings of very low safety significance (Green) are documented in this report. Three 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.
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 or a finding not associated with a regulatory requirement 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 Reactor Projects Branch D Division of Operating Reactor Safety Docket Nos. 05000313 and 05000368 License Nos. DPR-51 and NPF-6
Enclosure:
As stated
Inspection Report
Docket Nos:
05000313 and 05000368
License Nos:
Report Nos:
05000313/2024003 and 05000368/2024003
Enterprise Identifier:
I-2024-003-0000
Licensee:
Entergy Operations, Inc.
Facility:
Arkansas Nuclear One
Location:
Russellville, AR
Inspection Dates:
July 1, 2024, to September 30, 2024
Inspectors:
C. Alldredge, Health Physicist
N. Brown, Resident Inspector
T. DeBey, Resident Inspector
C. Harrington, Operations Engineer
S. Hedger, Senior Emergency Preparedness Inspector
R. Lanfear, Physical Security Specialist
K. Murphy, Operations Engineer
J. O'Donnell, Senior Health Physicist
H. Strittmatter, Resident Inspector
B. Tindell, Senior Resident Inspector
E. Tinger, Resident Inspector
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 Follow Pipe Thread Engagement Standards during Installation of Intermediate Cooling Water Piping Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000313/2024003-01 Open/Closed
[H.2] - Field Presence 71111.05 A self-revealed, Green finding was identified for the licensees failure to properly install Unit 1 intermediate cooling water piping associated with reactor coolant pump P-32C lift pump lube oil cooler in accordance with National Pipe Thread Tapered standard ASME B.1.20.1.
Specifically, the licensee did not meet the industry standard pipe thread engagement requirements when installing piping return lines into the lube oil cooler which resulted in a leak in the intermediate cooling water system and subsequent fill and overflow of the reactor coolant pump oil collection system.
Failure to Maintain Pressurizer Insulation Per Design Specifications Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000368/2024003-02 Open/Closed
[H.12] - Avoid Complacency 71111.20 The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the licensee failed to prescribe proper instructions, procedures, or drawings to control the removal and installation of insulation on the Unit 2 pressurizer (2T-1) dome.
Failure to Have a Standard Emergency Action Level Scheme in Use for Spent Fuel Casks Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000313,05000368/2024003-03 Open/Closed
[H.3] - Change Management 71114.04 The inspectors identified a Green finding and associated 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 have a standard emergency action level (EAL) scheme in use. The Unusual Event EAL threshold radiation levels that are intended to indicate damage to a loaded spent fuel cask confinement boundary were in error and would result in cases where classification would either not be declared when needed, would be overclassified, or would be declared in a degraded (delayed) manner.
Failure to Correct Excessive Vibrations Results in Service Water Valve Failure Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000313/2024003-04 Open/Closed
[H.5] - Work Management 71152A A self-revealed Green finding and associated non-cited violation of 10 CFR Part 50,
Appendix B, Criterion XVI, Corrective Action, was identified when the licensee failed to promptly identify and correct excessive vibrations, a condition adverse to quality, on Unit 1 service water train B supply to the intermediate water coolers, valve CV-3811, a quality-related valve. Specifically, the licensee identified the excessive vibrations following a failure of CV-3811 on February 11, 2023, but failed to correct the vibrations prior to an additional failure of the valve on June 5, 2024.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000313/2024-001-00 Source Range Nuclear Instrument Failure Resulting in Condition Prohibited by Technical Specifications 71153 Closed
PLANT STATUS
Unit 1 began the inspection period at full power and remained there for the duration of the inspection period.
Unit 2 began the inspection period at full power. The reactor started coasting down in power on September 1, 2024. On September 28, 2024, the licensee shut down the unit to begin refueling outage 2R30 and remained shut down 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) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1, turbine-driven emergency feedwater train B, while motor-driven emergency feedwater train A was out of service for maintenance, on July 11, 2024
- (2) Units 1 and 2, alternate ac diesel generator, while Unit 1 emergency diesel generator train B and Unit 2, turbine-driven emergency feedwater train B were out of service for maintenance, on July 18, 2024
- (3) Unit 1, makeup tank valve positions with the relief and vent valves out of service for maintenance, on August 7, 2024
- (4) Unit 2, instrument air system walkdown due to multiple compressor trips, on August 14, 2024
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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, safeguards pipeway south, area 40-Y, on August 15, 2024
- (2) Unit 2, auxiliary building corridor, area JJ, on August 23, 2024
- (3) Unit 2, control room, area 2199-G, on August 7, 2024
- (4) Unit 1, control room, area 129-F, on August 7, 2024
- (5) Unit 1, auxiliary building access corridor, area 98-J, on August 7, 2024
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 from June 10 to July 26, 2024.
- (2) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered between June 3 and July 19, 2024.
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 June 18, 2024.
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.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during the shutdown of Unit 2 for refueling outage 2R30, on September 28, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)
- (1) The inspectors observed and evaluated Unit 1 annual requalification operating test activities in the simulator, on July 17, 2024.
- (2) The inspectors observed and evaluated Unit 2 simulator evaluation and continued training, on August 16, 2024.
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) Unit 1, decay heat removal system, on July 26, 2024
- (2) Units 1 and 2, review of the 10 CFR 50.65(a)(3) periodic assessment, on July 29, 2024
Aging Management (IP Section 03.03) (1 Sample)
The inspectors evaluated the effectiveness of the aging management program for the following SSCs that did not meet their inspection or test acceptance criteria:
- (1) Unit 2, service water intake bays, due to concrete degradation and sluice gate obstruction, on August 9, 2024
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, emergent work for failure of containment spray train A valve 2CV-5612-1, on July 31, 2024
- (2) Unit 2, elevated risk due to motor-driven emergency feedwater train A planned maintenance, on August 5, 2024
- (3) Unit 2, elevated risk due to emergency diesel generator A planned maintenance, on August 26, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 1, turbine driven emergency feedwater train B, operability determination due to oil leakage, on July 17, 2024
- (2) Unit 2, charging pumps, functionality assessment due to oil leakage, on July 17, 2024
- (3) Unit 2, emergency cooling pond sluice gate, 2CV-1471-1, operability determination due to leakage, on August 23, 2024
- (4) Units 1 and 2, alternate ac diesel generator, functionality assessment due to isolation of fuel oil makeup, on August 27, 2024
- (5) Unit 2, emergency diesel generator train A, operability determination due to exhaust silencer wall thinning, on September 25, 2024
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Partial)
(1)
(Partial)
The inspectors evaluated Unit 2 refueling outage 2R30 activities from September 28, 2024, through September 30, 2024. The inspectors completed inspection procedure sections 03.01.a through 03.01.b.
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) (10 Samples)
- (1) Unit 1, emergency feedwater train A flow control valve CV-2648 post-maintenance test following maintenance and calibration, on July 11, 2024
- (2) Unit 1, service water pump train B post-maintenance test after pump overhaul, on July 17, 2024
- (3) Unit 1, emergency diesel generator train B post-maintenance test after speed sensor replacement, on July 24, 2024
- (4) Unit 2, motor-driven emergency feedwater pump train A post-maintenance test after maintenance, on August 14, 2024
- (5) Unit 2, upstream atmospheric dump valve 2CV-1051 post-maintenance test after repair, on August 15, 2024
- (6) Unit 1, service water train B inlet to decay heat cooler valve CV-3821 post-maintenance test after maintenance, on August 21, 2024
- (7) Unit 2, service water valve to spent fuel cooler valve 2CV-1526-2 post-maintenance test after maintenance, on September 18, 2024
- (8) Unit 2, emergency diesel generator train A post-maintenance test following maintenance, on September 18, 2024
- (9) Units 1 and 2, common feedwater pump train B post-maintenance test after maintenance, on September 19, 2024
- (10) Unit 1, service water to emergency cooling pond valve CV-3823 post-maintenance test after maintenance, on September 25, 2024
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) Unit 2, turbine-driven emergency feedwater train B inservice testing, on July 17, 2024
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:
- OP 1903.010, Emergency Action Level Classification, revision 62 (NRC notified on September 5, 2023)
- ANO Emergency Plan, revision 49, and On-Shift Staffing Analyses, revision 3 (NRC notified on October 11, 2023)
- ANO Emergency Plan, revision 50 (NRC notified on January 17, 2024) [List submitted change and date]
Several screenings and evaluations associated with the 10 CFR 50.54(q) emergency plan change process were reviewed as well. These evaluations do not constitute NRC approval.
71114.06 - Drill Evaluation
Additional Drill and/or Training Evolution (1 Sample)
The inspectors evaluated:
- (1) emergency operating facility drill on loss of all AC power event, on July 18, 2024
71114.07 - Exercise Evaluation - Hostile Action (HA) Event
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the biennial emergency plan exercise conducted on August 20, 2024. The exercise scenario simulated a coordinated attack on the plant site and rapid escalation to a site area emergency classification which resulted in staffing the alternative response facilities. An explosion in the spent fuel cask loading area resulted in a simulated radiological release offsite concurrent with a fire necessitating fire and medical personnel response.
71114.08 - Exercise Evaluation - Scenario Review
Inspection Review (IP Section 02.01 - 02.04) (1 Sample)
- (1) The inspectors reviewed the licensees preliminary exercise scenario that was submitted to the NRC on June 13, 2024 (Agencywide Documents Access and Management System [ADAMS] Accession No. ML24169A275 and -276), for the exercise scheduled on August 20, 2024. The inspectors discussed the preliminary scenario comments with Subrena Morris, Manager, Emergency Preparedness, and other members of the emergency preparedness staff on July 11, 2024. 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) (5 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
(1)portable friskers in use in Unit 1 and Unit 2 auxiliary building (2)continuous air monitors in use in Unit 1 and Unit 2 auxiliary building (3)personnel contamination monitors and portal monitors in use at the control access point in Unit 1 (4)tool and equipment monitors in use in Unit 1 auxiliary building and radiation protection support shop (5)area radiation monitor in Unit 2 cask washdown area, elevation 404
Calibration and Testing Program (IP Section 03.02) (12 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) FASTSCAN whole body counter
- (2) Ludlum-177, SN CHP-CR-179
- (3) ARGOS-004, SN 1211-206
- (4) GEM-006, SN 1612-318 (5)2000 (43-10), SN 357729
- (6) Cronos-001, SN 1403-034
- (7) Unit 1 containment high range monitor, RE-8060
- (8) Unit 2 containment high range monitor, 2RE-8925-1
- (9) AMS-032, SN 1160
- (10) AMP-100, SN CHP-ARM070 (11)9-3, SN CHP-DR-346
- (12) Telepole II, SN CHP-Tel189 Effluent Monitoring Calibration and Testing Program Sample (IP Section 03.03) (3 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
- (1) Unit 2 hydrogen purge/gas, 2RITS-8231-1B
- (2) Unit 1 liquid radwaste monitor, RE-4642
- (3) Unit 1 SPING 2 radwaste area vent monitor, RX-9825
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)the old radioactive waste storage facility (2)the new radioactive waste storage facility
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 equipment drain system
- (2) Unit 2 equipment drain system
Waste Characterization and Classification (IP Section 03.03) (2 Samples)
The inspectors evaluated the following characterization and classification of radioactive waste: (1)dry active waste for 2021, 2022, and 2023 (2)2022 secondary resin for Unit 1 and Unit 2
Shipment Preparation (IP Section 03.04) (1 Sample)
- (1) The inspectors observed the preparation of radioactive shipment RSR-24-062, a high integrity container of resin, LSA-II, on July 11, 2024.
Shipping Records (IP Section 03.05) (5 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through a record review:
- (1) RSR-22-058, SEDS equipment in a 10-foot intermodal container, SCO-II
- (2) RSR-22-089, mechanical filters in a high integrity container/cask, LSA-II
- (3) RSR-23-046, Unit 2 'B' reactor coolant pump seal, Type A
- (4) RSR-23-080, mechanical filters in a high integrity container/cask, LSA-II
- (5) RSR-24-052, dry active waste in a high integrity container, LSA-II
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, 2023, through June 30, 2024)
- (2) Unit 2 (July 1, 2023, through June 30, 2024)
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
- (1) Unit 1 (July 1, 2023, through June 30, 2024)
- (2) Unit 2 (July 1, 2023, through June 30, 2024)
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
- (1) Unit 1 (July 1, 2023, through June 30, 2024)
- (2) Unit 2 (July 1, 2023, through June 30, 2024)
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
- (1) July 1, 2023, through June 30, 2024 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
- (1) July 1, 2023, through June 30, 2024 EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
- (1) July 1, 2023, through June 30, 2024
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, effectiveness of corrective actions related to an overflow of the borated water storage tank, on August 22, 2024
- (2) Unit 1, effectiveness of corrective actions related to a failure to close of service water train B supply to the intermediate water coolers valve CV-3811, on September 23, 2024
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensees event reporting determinations to ensure it complied with reporting requirements.
- (1) LER 05000313/2024-001-00, Source Range Nuclear Instrument Failure Resulting in Condition Prohibited by Technical Specifications (Agencywide Documents Access and Management System [ADAMS] Accession No. ML24183A214). The inspection conclusions associated with this LER are documented in Inspection Report 05000313/2024002 (Accession No. ML24219A019) under Inspection Results Section 71153. This LER is Closed.
INSPECTION RESULTS
Failure to Follow Pipe Thread Engagement Standards during Installation of Intermediate Cooling Water Piping Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000313/2024003-01 Open/Closed
[H.2] - Field Presence 71111.05 A self-revealed, Green finding was identified for the licensees failure to properly install Unit 1 intermediate cooling water piping associated with reactor coolant pump P-32C lift pump lube oil cooler in accordance with National Pipe Thread Tapered standard ASME B.1.20.1.
Specifically, the licensee did not meet the industry standard pipe thread engagement requirements when installing piping return lines into the lube oil cooler which resulted in a leak in the intermediate cooling water system and subsequent fill and overflow of the reactor coolant pump oil collection system.
Description:
On October 26, 2023, the licensee identified a lowering level on the surge tank for the non-nuclear loop of the Unit 1 intermediate cooling water (ICW) system. An increasing reactor building sump level and multiple alarms associated with reactor coolant pump (RCP)
P-32C air cooler level transmitter indicated a leak in the ICW system. On December 4, 2023, due to an increasing leak rate, Unit 1 shut down, and the licensee entered the reactor building to determine the location of the leak. Operators identified a crack approximately three-eighths of an inch from the end of a threaded connection associated with the RCP P-32C lift pump lube oil cooler. The crack was approximately 50 percent around the pipe section, and ICW water was leaking from the system.
As documented in condition report CR-ANO-1-2023-01609, the licensee discovered that during the ICW pipe assembly and installation process in the April 2021 refueling outage, the contractors installing the pipe section failed to follow the industry pipe thread engagement standard, National Pipe Thread Tapered (NPT) standard ASME B.1.20.1, which led to improper pipe thread engagement and overtightening. Specifically, the installers assembled the pipe using their rule of thumb of approximately 3 turns wrench tight which is not in alignment with the industry standard of 7.46 threads wrench tight. The lack of thread engagement caused the pipe section to be overtightened and increased the stress on the pipe resulting in a crack in the lower threaded connection to the RCP P-32C lift pump lube oil cooler.
The RCP oil collection system provides the capability to collect oil from the RCP motor and safely contains the oil leakage in a drain tank to prevent fire hazards. The leaking ICW water filled the RCP P-32C and P-32D oil collection system drain tank, T-90, causing the tank to overflow to the surrounding berm, and the berm to overflow to the reactor building floor.
During this period, oil from RCPs P-32C and P-32D would have been routed to the oil collection system, but the oil collection drain tank, T-90, would not contain the oil leakage, resulting in a degradation of fire prevention controls.
Corrective Actions: The licensee removed and replaced the cracked pipe in the Unit 1 ICW system. Additionally, operators drained the oil collection drain tank, T-90, and surrounding berm to remove the water that had collected in the system.
Corrective Action References: Condition Reports CR-ANO-1-2023-01498 and CR-ANO-1-2023-01609
Performance Assessment:
Performance Deficiency: The licensees failure to properly install Unit 1 ICW piping associated with RCP P-32C lift pump lube oil cooler in accordance with NPT standard ASME B.1.20.1 was a performance deficiency. Specifically, the licensee did not the meet the industry standard pipe thread engagement requirements when reinstalling the piping return lines into the RCP P-32C lube oil cooler which resulted in a leak in the ICW system and subsequent fill and overflow of the RCP oil collection system.
Screening: The inspectors determined the performance deficiency was more than minor, and therefore a finding, because it was associated with the Protection Against External Factors 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 leak filled the RCP oil collection drain tank, T-90, with water, which adversely affected the system from being able to perform its fire prevention function of collecting RCP oil and safely containing it. During this period, T-90 did not have the capability of collecting and containing oil from RCP P-32C and P-32D. Additionally, the licensee was required to perform a forced shutdown of Unit 1 to determine the location and extent of the leakage from the ICW system.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix F, Fire Protection Significance Determination Process, issued May 2, 2018.
Specifically, the inspectors used IMC 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, issued May 2, 2018. The inspectors categorized the finding as an element covered by fire prevention and administrative controls.
Using IMC 0609, Appendix F, Attachment 2, the inspectors assigned the finding a low degradation rating. This was due to the RCP oil being a high flashpoint oil that would have overflowed onto the ground around T-90 without contacting any ignition sources. Therefore, the finding was determined to be of very low safety significance (Green).
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, the licensee failed to ensure the contractors involved in assembly and installation of the ICW piping followed the industry pipe thread engagement standard, NPT standard ASME B.1.20.1.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
Failure to Maintain Pressurizer Insulation Per Design Specifications Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000368/2024003-02 Open/Closed
[H.12] - Avoid Complacency 71111.20 The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the licensee failed to prescribe proper instructions, procedures, or drawings to control the removal and installation of insulation on the Unit 2 pressurizer (2T-1) dome.
Description:
During a walkdown of the Unit 2 containment during the spring 2023 refueling outage 2R29, the inspectors identified that the insulation on the top of the pressurizer (2T-1)did not appear to be configured correctly. The pressurizer head insulation is removed during refueling outages so planned work on pressurizer relief valves can be performed. Then, the insulation is reinstalled before the unit startup. After the inspectors identification, the licensee checked the insulation and verified that there was missing and degraded insulation.
Specifically, there was missing insulation on two lifting lugs, on the pressurizer nameplate and nearby area, around the spray nozzle penetration and nearby area, a gap between two insulation pads, and missing metal mesh on the outside of one insulation blanket. An operability determination was performed, and it concluded that the missing insulation did not cause a concern for containment sump debris, did not challenge pressurizer heater operability, and did not have a significant effect on containment ambient temperature.
The ANO Unit 2 UFSAR, section 5.5.10.2 states that 150 kW of pressurizer capacity powered from an assured power source will ensure, for 588,000 BTU/hr ambient losses, that reactor coolant system subcooling margin will be maintained >20 °F for a period of 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> following loss of off-site power. This time period includes a period of one-half hour at the beginning of the transient in which the heaters are unavailable. Actual heat losses from the pressurizer, from startup testing data, is 596,000 BTU/hr or 8,000 BTU/hr greater than that assumed above. However, this 8,000 BTU/hr increase in losses would only require a 2.345 kW increase to offset this loss increase and, therefore, will have little impact on the 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> calculated above. Although the plant met the technical specification requirement for heater capacity, the missing insulation challenged the UFSAR evaluation and would also challenge the pressurizer function of maintaining subcooled conditions in the reactor cooling system during accident conditions. Removal of the insulation was not planned or evaluated by site personnel.
In condition report CR-ANO-2-2023-01598, the licensee stated that the effect on the structure system component safety function was, The purpose of the insulation is to provide protection of the RCS system from ambient losses and aid in maintaining the Containment environment within design limits during normal and Post Accident Conditions. The amount of surface area that has been left uncovered will result in a negligible amount of heat transfer to the containment building during normal and accident conditions. The deficient insulation on the pressurizer head was not considered nor objectively evaluated for the negative effect on time to lose subcooling margin during a loss of offsite power such that it was within the analysis in the UFSAR. Since the UFSAR identifies that the pressurizer heater capacity required by the technical specifications is less than the pressurizer ambient heat losses, any increase in ambient heat loss caused from missing insulation will shorten the time to lose subcooling and challenge the units ability to maintain natural circulation flow so that core damage can be avoided.
In condition report CR-ANO-C-2023-0049, the licensee identified that there was not a formal process nor procedure in place to ensure ANO is meeting the commitment for engineering review of insulation removal tasks on safety-related equipment. The licensees commitment was to track insulation that was removed from a safety-related system. The process/procedure deficiency existed from 2009 until 2023. This issue may have contributed to the missing insulation on the Unit 2 pressurizer head.
Corrective Actions: The immediate corrective actions were to fabricate and install temporary insulation pads that would meet the design criteria for the locations that had missing insulation. Permanent replacement pads were scheduled to be installed during the subsequent refueling outage.
Corrective Action References: Condition Report CR-ANO-2-2023-01598 and Work Order 595647
Performance Assessment:
Performance Deficiency: The failure to maintain the Unit 2 pressurizer insulation so that ambient heat losses are within design limits 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, and therefore a finding, because it was associated with the Design Control 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 performance deficiency adversely affected that objective because the insufficient pressurizer insulation would challenge the heater capability to maintain reactor coolant system subcooling margin to support natural circulation decay heat removal using the steam generators during an extended loss of offsite power.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. 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. 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. To determine this significance, the analyst used the ANO Unit 2, SPAR model, version 8.82, run on SAPHIRE, version 8.2.11, which the analyst modified to reflect the conditions where only one train of pressurizer heaters would be available, namely losses of one of the class 1E safety buses. Additionally, the analyst modified the SPAR model by adding a top event in the loss of offsite power event trees which reflected the strategies to maintain adequate subcooling margin. The fault tree under this top event contained pressurizer heater failures (whose capacity was deemed inadequate by the performance deficiency) and operator actions to maintain subcooling margin. The analyst constructed 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 analyst estimated operators would have approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-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 was very low (Green).
The analyst referenced IMC 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: 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 missing pressurizer insulation was not recognized by the insulation workers, system engineers, or plant operations employees. It appears that the insulation may have been missing for an extended period of time and had become normalized.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion V states, in part, Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to above, prior to May 2023, the licensee failed to prescribe and accomplish activities affecting quality in accordance with instructions, procedures, or drawings appropriate to the circumstances. Specifically, the licensee failed to maintain the Unit 2 pressurizer insulation per its design such that ambient heat loss is within the value analyzed in the UFSAR. Appropriate procedures for removal and installation of primary SSC insulation did not exist at the site for performing the associated duties.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
Failure to Have a Standard Emergency Action Level Scheme in Use for Spent Fuel Casks Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000313,05000368/2024003-03 Open/Closed
[H.3] - Change Management 71114.04 The inspectors identified a Green finding and associated 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 have a standard emergency action level (EAL) scheme in use. The Unusual Event EAL threshold radiation levels that are intended to indicate damage to a loaded spent fuel cask confinement boundary were in error and would result in cases where classification would either not be declared when needed, would be overclassified, or would be declared in a degraded (delayed) manner.
Description:
The inspectors reviewed a recent revision to the licensees EAL scheme.
Procedure 1903.010, Emergency Action Level Classification, revision 62, documented changes made to EAL EU1.1, which provides radiation levels which are used as Unusual Event classification criteria for loaded cask confinement boundary damage at the licensees independent spent fuel storage installation (ISFSI). The Unusual Event criteria are supposed to be based on the maximum allowable radiological dose rates specified in a spent fuel cask models technical specifications (part of its Certificate of Compliance). Therefore, different cask models might have different dose rates specified.
One of the changes implemented by the procedure revision was to incorporate additional dose rate thresholds for the Unusual Event criteria for Holtec Hi-Storm 100 spent fuel casks that were different than those previously shown for that cask model. Dose rates associated with this model of spent fuel cask were included as part of an EAL license amendment request that was approved on January 17, 2019 (ML18337A247), and implemented in Procedure 1903.010, revision 59 (effective date January 14, 2020). At the time of the license amendment, there were five vintages of Holtec Hi-Storm 100 casks that were in use by the licensee, with four different Technical Specification maximum radiological dose rate values.
However, the licensee only included the threshold values for the latest cask model in the EAL license amendment request, instead of including all of the prior cask model thresholds, which were still in use as well.
The net result was that from January 14, 2020, to September 25, 2024, the approved EAL EU1.1 in use did not include accurate thresholds for all of the cask models. This failure to include accurate thresholds for each of the different cask models in the EAL meant that the EAL EU1.1 did not have the correct radiation threshold values for most of the casks in use.
Therefore, it would have been possible that, for some casks, indicated radiation levels that should have resulted in a declaration of EU1.1 would not have resulted in a declaration, or would have been delayed. There was also one example where indicated radiation levels that should not have resulted in a declaration of EU1.1 might have been overclassified.
The inspectors determined that, with respect to EAL EU1.1 within their emergency classification scheme, the licensee did not provide adequate criteria to ensure that appropriate emergencies could be classified for all spent fuel casks in their ISFSI. 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. In addition, a standing order was put in place, communicating to the emergency response organization what the correct classifications thresholds are for EAL EU1.1 (September 25, 2024).
Corrective Action References: Condition Reports CR-ANO-C-2024-01642, CR-ANO-C-2024-01742, and CR-HQN-2024-01039
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to provide a standard scheme of emergency action levels 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, and therefore a finding, because it was associated with the Procedure Quality 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 maintain an accurate set of emergency action level criteria for use in radiological emergencies.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix B, Emergency Preparedness SDP. 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 this affected the ability to classify cases of an Unusual Event, and other emergency classification criteria for other conditions that would lead to classifications up to a General Emergency were unaffected by this issue.
Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.
The licensee did not use a systematic process for evaluating and implementing changes.
Specifically, the change processes exemplified with the issue (license amendment, emergency plan) did not account for all the pertinent accurate information to ensure there were correct outcomes, and opportunities to evaluate failures and improve future performance were missed.
Enforcement:
Violation: Title 10 CFR 50.54(q)(2) requires, in part, 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)(4) requires, in part, that the a standard emergency classification and action level scheme is in use by the nuclear facility licensee. Arkansas Nuclear One Procedure OP-1903.010, revisions 59 through 62, constitute the licensees emergency classification and action level scheme, and is part of their emergency plan.
Contrary to the above, between January 14, 2020, and September 25, 2024, 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 have a standard emergency classification and action level scheme in use. Procedure OP-1903.010 contained emergency classification thresholds in EAL EU1.1 that in cases rendered it ineffective such that an Unusual Event would not be declared or declared in a degraded manner for a particular off-normal event.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
Failure to Correct Excessive Vibrations Results in Service Water Valve Failure Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000313/2024003-04 Open/Closed
[H.5] - Work Management 71152A A self-revealed Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was identified when the licensee failed to promptly identify and correct excessive vibrations, a condition adverse to quality, on Unit 1 service water train B supply to the intermediate water coolers, valve CV-3811, a quality-related valve. Specifically, the licensee identified the excessive vibrations following a failure of CV-3811 on February 11, 2023, but failed to correct the vibrations prior to an additional failure of the valve on June 5, 2024.
Description:
On June 5, 2024, Unit 1 service water train B supply to the intermediate water coolers, valve CV-3811, failed to stroke closed when operators attempted to close the valve from the control switch in the control room. Operators declared train B of service water inoperable because CV-3811 would not have been able to perform its safety function to isolate non-seismic portions of service water piping on an Engineered Safeguards signal. The licensee performed troubleshooting and discovered a broken lug within the valve actuator that, when not providing electrical continuity, prevented the valve from closing. On the same day as the failure, the licensee replaced the lug.
The licensee performed a causal evaluation that determined that the lug had broken, and therefore caused the valve to fail, due to excessive vibrations of the valve actuator.
Specifically, the lug had failed due to fatigue caused by vibrations. The licensee performed testing and determined that the valve vibrated in resonance when the system was throttled during periods when service water is cold. The licensee evaluated system modifications and procedure changes to limit vibrations of CV-3811 and plans to implement corrective actions prior to the next period when service water is cold.
The licensee reviewed the history of CV-3811 and noted that the valve failed February 11, 2023. In 2023, the licensee had performed a causal evaluation due to the valve failure, documented in Condition Report CR-ANO-1-2023-00277, and determined that CV-3811 experienced excessive vibrations. The licensee developed work orders to inspect the surrounding pipe supports and restore them to design (WO 594171), and another action to develop a modification to dampen the vibration (corrective action 18 of the condition report).
Subsequently, the licensee inspected the pipe supports and found no problems. The work order was closed with no further action planned. The licensee also closed corrective action 18 by documenting that the piping configuration did not meet the design, which conflicted with the detailed piping inspection performed under WO 594171. Therefore, the licensee closed all of the documents and processes that were tracking the correction actions for excessive vibrations of CV-3811 without correcting the condition that adversely affected the reliability of the valve operator.
The inspectors reviewed control room logs and determined that the valve had been successfully stroked on May 9, 2024, and then remained open until the failure on June 5, 2024. Therefore, the inspectors determined that the lug failure due to vibration occurred sometime between these two dates.
Corrective Actions: The licensee replaced the broken lug and tested the valve. Subsequently, the licensee analyzed the vibrations and plans to reduce future vibrations by either modifying the system or imposing procedural restrictions on flow that cause the vibrations.
Corrective Action References: Condition Report CR-ANO-1-2024-01328
Performance Assessment:
Performance Deficiency: The failure to promptly identify and correct excessive vibrations on service water train B supply to the intermediate water coolers, valve CV-3811, was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor, and therefore a finding, 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 excessive vibrations adversely impacted the reliability of CV-3811, a valve required for operability of Unit 1, service water train B, a system that responds to initiating events to prevent undesirable consequences.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, issued November 30, 2020, and used Exhibit 4, External Events Screening Questions. The inspectors determined this finding required a detailed risk evaluation because CV-3811 is specifically designed to isolate non-seismically designed service water piping. The valve was exposed to excessive vibrations and was likely in a failed state for more than 14 days between May 9, 2024, when it was successfully stroked, and June 5, 2024, when the failure was revealed. The loss of this equipment by itself during a seismic event would degrade one train of service water, a risk-significant system. 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. For this significance determination, the analyst used ANO Unit 1, SPAR model, version 8.8.1, run on SAPHIRE, version 8.2.11, to estimate the increase in core damage frequency. The increase in core damage frequency was assumed to be comprised of two parts, one for the time since the last successful stroke of the valve and the other for the failure of the valve for a postulated year during which a possible seismic event would vibrate the valve and render it unavailable. For the first aspect, the analyst used a 30-day exposure time (from May 9 to June 5, 2024, plus an assumed 3 days of repair time) assuming that the valve was set up for failure after its last successful stroke on May 9, 2024. The analyst set basic event SWS-MOV-OO-CV3811, Failure to Isolate the ICW from Service Water Loop II, to TRUE which incorporated the potential for common cause failure of similar valve CV-3820. The increase in core damage frequency from this portion of the estimate was 1.57E-7/year. For the second aspect, the analyst set basic event SWS-MOV-OO-CV3811, Failure to Isolate the ICW from Service Water Loop II, to TRUE, for 1 year and ran just the seismic events in the model. This method estimated an increase in core damage frequency for the second portion. The analyst combined the two estimates to obtain a total increase in core damage frequency from external events of 2.0E-8/year. Upon reviewing the increase in core damage frequency from external events for the 30-day exposure time, the analyst noted that the other external events, such as fire, tornado, and high wind events were not significant contributors to the increase in core damage frequency. The analyst referenced IMC 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. The analyst subsequently concluded that the total increase in core damage frequency was 1.8E-7/year, making the significance of the finding very low (Green). The dominant accident sequences were total losses of the service water system. Operator action for restoration of the opposite train of the service water system were important mitigators to core damage.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the licensee planned and implemented work orders to correct the excessive vibration of CV-3811 following the 2023 failure, but the work orders were closed without correcting the condition, and the licensee failed to coordinate the work to ensure that someone continued attempts to correct the excessive vibrations.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
Contrary to the above, between February 11, 2023, to June 5, 2024, the licensee failed to promptly identify and correct excessive vibrations, a condition adverse to quality, on CV-3811, Unit 1 service water train B supply to the intermediate water coolers, a quality-related valve. Specifically, the licensee identified the excessive vibrations following a failure of CV-3811 on February 11, 2023, but did not correct the vibrations prior to an additional failure of the valve on June 5, 2024.
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 11, 2024, the inspectors presented the emergency preparedness exercise scenario inspection results to Subrena Morris, Manager, Emergency Preparedness, and other members of the licensee staff.
- On July 12, 2024, the inspectors presented the public radiation safety inspection results to Mark Skartvedt, General Manager of Plant Operations, and other members of the licensee staff.
- On August 19, 2024, the inspectors presented the IP 71111.11 A/B inspection results to Frank Shewmake, Operations Director, and other members of the licensee staff.
- On October 11, 2024, the inspectors presented the emergency preparedness exercise inspection results to Doug Pehrson, Site Vice President, and other members of the licensee staff.
- On October 18, 2024, the inspectors presented the integrated inspection results to Doug Pehrson, 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-
1-2024-00577, 1-2024-01141, 2-2023-01523, 2-2023-01894,
C-2013-01870
Drawings
M-231, Sheet 1
Piping and Instrumentation Diagram Makeup & Purification
System
116
ER002592E101
MU Tank Vent Path Isolation
004-03-0
ER980331E101
Makeup Tank, T-4, Pressure vs. Level Curve Validation for
STM 1-27
STM 2-33
Alternate Ac Diesel Generator
Miscellaneous
STM 2-42
Service Water & Auxiliary Cooling Water Systems
OP-1106.006
Emergency Feedwater Pump Operation
2
OP-1305.034
Makeup Tank Relief Path Isolation Controls
OP-2104.037
Alternate AC Diesel Generator Operations
Procedures
OP-2202-.008
Station Blackout
Work Orders
Corrective Action
Documents
CR-ANO-
1-2018-02886, C-2021-01265
Drawings
A-2117
Architectural Miscellaneous Interior Elevations
Unit 1 Prefire Plans
Fire Plans
Unit 2 Prefire Plans
DCR 2-30
Memo: Arkansas Nuclear One - Unit 2 Completed
DCR/DCP (File: 2-0135.1)
04/04/1979
Fire Hazards Analysis
Miscellaneous
TRM-3.7.10
Technical Requirements Manual - Control Room Halon
Systems
OP-1003.014
OP-1104.032
Fire Protection Systems
OP-1307.012
Unit 1 Fire Detection Performance Test
Procedures
OP-2203.049
Fires in Areas Affecting Safe Shutdown
Miscellaneous
IP71111.11, 3.03,
Table 1
Requalification Examination Results
08/19/2024
Miscellaneous
ANO2 Vision Exam Overlap RO/SRO
07/03/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Week 2 RO Written Exam
Week 2 SRO Written Exam
Week 3 RO Written Exam
Week 3 SRO Written Exam
Operating Crew Attendance Records
Biennial Comprehensive Written Exam Scores Weeks 1 - 6
Reviewed six licensed operator medical records.
Use 2Y3 to Supply Alarm and Control Power to 2C343
ASDCR
Perform Alternate Shutdown
AACFO
Control AAC Diesel Engine Fuel Oil Day Tank Level
Manually
AOP04
Disable B Channel Excore Nuclear Instrumentation
CNTCL1
Verify Containment Coolers in Emergency Mode
CPC06
Place #1 CEAC to INOP on "B" CPC
Swap 2D-31B and 2D-31A Battery Chargers
ELEC6
Transfer Auxiliaries from SU#2 to SU#3 for 2A-2
A2JPM-RO-RSD3
Perform a Remote Shut Down as an CBOT
RWTMU
Determine Volume of Boric Acid and DI Water to Makeup to
SFPMU
Spent Fuel Pool Makeup
SIT Isolation
SW04
Temporary Shifting of Service Water Pumps to Allow
Discharge Strainer Settling
SWPDC
Operate the Service Water Pump Disconnects Manually
EAL27
Classify an Emergency Event
SES-2-006
Dynamic Exam Scenario
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
SES-2-007
Dynamic Exam Scenario
SES-2-061
Dynamic Exam Scenario
SES-2-071
Dynamic Exam Scenario
DG-TRNA-015-
EXAMSEC
Simulator Exam Security Guidelines
EN-OP-115-06
Activation and Reactivation of Licenses
EN-OP-115-06
License Watch Station Activation/Reactivation (5 Operators)
Conduct of Simulator Training
License Operator Requalification Annual and Biennial Exam
Development
TQF-201-IM05
Remedial Training Plan (4 Operators, 1 Crew Records)
TQF-214-71111
71111.11 Pre-Assessment - Unit 2 LOR 2024
Procedures
TQF-218-
AOESIM
Annual Operating Exam Simulator Scenario Set Quality
Checklist
250104
Miscellaneous
SES-1-032
Conduct of Operations
EN-OP-115-02
Control Room Conduct and Access Control
OP-2102.004
Power Operation
OP-2202.001
Standard Post Trip Actions
OP-2202.011
Lower Mode Functional Recovery
Procedures
OP-2203.029
Loss of Shutdown Cooling
Corrective Action
Documents
CR-ANO-
1-2024-00704, 2-2021-03145, 2-2022-00056, 2-2022-02279,
2-2023-02175, 2-2023-03014, 2-2024-00046, 2-2024-00809
Drawings
M-2210, Sheet 5
Piping and Instrument Diagram Service Water System
Corrosion Inhibitor Injection
Engineering
Changes
Unit 2 Service Water Chemical Injection TMOD
03/19/2021
CALC-ANO2-ME-
15-00023
Review of the Service Water Integrity Program for License
Renewal Implementation
Miscellaneous
CALC-ANOC-SE-
Maintenance Rule 10CFR50.65(a)(3) Periodic Assessment 1 0
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
23-00001
January 2022 to 30 June 2023
Condition Monitoring of Maintenance Rule Structures
19
Arkansas Nuclear One Maintenance Rule Structures
Maintenance Rule Scope and Basis
Procedures
OP-1412.054
Unit 1 AC Motor Control Centers
Work Orders
WO 5415855, 554899, 572588, 52807696, 52900485,
54027517, 54027518, 54149261
Corrective Action
Documents
CR-ANO-
2-2013-00992
0467-2P-7B
Protected Train for 2P-7B Inoperable for Maintenance
08/02/2024
Miscellaneous
0481
Protected Train U2 Protected Train #1 EDG Outage
08/23/2024
COPD-013
Operations Maintenance Interface Standards and
Expectations
COPD-024
Risk Assessment Guidelines
Protected Equipment Postings
Procedures
OP-2104.036
Emergency Diesel Generator Operations
104
Corrective Action
Documents
CR-ANO-
1-2023-01565, 1-2024-01525, 2-2024-00266, 2-2024-00809,
2-2024-01126, 2-2024-01149, 2-2024-01169, 2-2024-01195,
C-2022-02338
Operability Determination Process
On-Line Risk Assessment
OP-2305.018
Underground EDG F.O. Tank 2T-57A/B Recirculation and
Cleanup
Procedures
OP-2628.013
Operation of Unit 2 Service Water Corrosion Inhibitor
Injection System
Work Orders
WO 53008244, 54086015, 54109689, 54149261
Miscellaneous
OL-ANO-2024-
00011
2R30 Outage Risk Assessment Team Report
09/19/2024
OP-1015.008
Unit 2 SDC Control
OP-2102.004
Power Operation
Procedures
OP-2102.010
Plant Cooldown
Corrective Action
CR-ANO-
1-2021-02566, 1-2022-00606, 1-2022-02451, 1-2023-00105,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
1-2023-00573, 1-2024-00437, 2-2024-00026, 2-2024-00901,
2-2024-01017, 2-2024-01025
Documentation of Baseline for ANO2 Reference Values for
08/29/2018
Speed Switches SS-5210 and SS-5220 Are Obsolete
04/30/2009
Update Setpoint for EDG Air Start Motor Solenoids
07/28/2023
Engineering
Changes
Update Setpoint for K-4B Air Start Motor Solenoids
07/28/2023
ER-ANO-2003-
0062
MAI 69129 2CV-1051 PMT Results
01/20/2003
Engineering
Evaluations
PMEE-115
Preventive Maintenance Engineering Evaluation: Emergency
Feedwater Pump
SEP-ANO-1-IST-
ANO Unit 1 Inservice Testing Plan Document
SEP-ANO-2-IST-
ANO Unit 2 Inservice Testing Bases Document
U2 Log
Unit 2 Narrative Log entry 8/19/2024, 1117
8/19/2024
Miscellaneous
U2 Log
Unit 2 Narrative Log Entry 08/05/2024, 1645
08/05/2024
Limitorque Valve Operator Model SMB/SB/SBD-000
Through 5 MOV and HBC Periodic Inspection
Overhaul of Limitorque SMB000 & SB/SMB 00 Actuators
EN-OP-115-16
Safety Function Determination and LCOTR Processes
OP-1104.004
Decay Heat Removal Operating Procedure
140
OP-1104.029
Service Water and Auxiliary Cooling System
28
OP-1104.036
Emergency Diesel Generator Operation
OP-1106.006
Emergency Feedwater Pump Operation
2
OP-1106.007
Common Feedwater System
OP-1305.007
RB Isolation and Miscellaneous Valve Stroke Test
OP-1404.002
EFW Flow Control Valves Maintenance
OP-1412.038
Unit 1 Service Water Pump Lubrication and Inspection
OP-2104.036
Emergency Diesel Generator Operations
104
OP-2106.006
Emergency Feedwater System Operations
111
OP-2305.003
ESF Response Time Test
Procedures
OP-2305.005
Valve Stroke and Position Verification
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
OP-2402.014
Unit 2 Emergency Feedwater (2P-7A & B) Maintenance
Work Orders
WO 565424, 566316, 591542, 593978, 53023736, 53029355,
53030467, 53030513, 53030674, 53031381, 53031479,
53032686, 54045386, 54135118, 54168707, 54172594,
54174248, 54176290,
Condition Reports
(CR-ANO-C-)
24-01412, 2024-01445, 2024-01642, 2024-01742, 2024-
01743
Corrective Action
Documents
Resulting from
Inspection
Corporate
Condition Reports
(CR-HQN-)
24-01039
Engineering
Changes
EC#: 0000091669
Holtec Dry Fuel Storage Upgrade - HI-STORM FW System
Transition for ANO Unit 1
CFR 50.54(q)(3) Screening; ANO Units 1 and 2; Title:
ANO Emergency Plan, Revision: 49
07/28/2022
CFR 50.54(q)(3) Evaluation; ANO Units 1 and 2; Title:
ANO Emergency Plan, Revision: 49
07/27/2022
CFR 50.54(q)(3) Evaluation; ANO Units 1 and 2; Title:
ANO Emergency Plan, Revision: 49
09/22/2022
Arkansas Nuclear One, On-Shift Staffing Analysis Final
Report
0, 1, 2, 3
CFR 50.54(q)(3) Evaluation; Arkansas Nuclear One;
Procedure Number: OP-1903.010; Title: Emergency Action
Level Classification; revision: 062
06/19/2023
CFR 50.54(q)(3) Screening; ANO Units 1 and 2; Title:
ANO Emergency Plan, Revision: 50
11/27/2023
CFR 50.54(q)(3) Evaluation; ANO Units 1 and 2; Title:
ANO Emergency Plan, Revision: 50
11/27/2023
CFR 50.54(q)(3) Screening; Arkansas Nuclear One; Title:
22 Evacuation Time Estimate Impact on Protective Action
Recommendations
09/07/2023
Miscellaneous
0CAN012402
Arkansas Nuclear One (ANO) Emergency Plan Revision 50;
Arkansas Nuclear One - Units 1 and 2; NRC Docket Nos.
50-313, 50-368, and 72-13; Renewed Facility Operating
01/17/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
0CAN082201
License Amendment Request for Approval of Changes to
the Emergency Plan Staffing Requirements; Arkansas
Nuclear One - Units 1 and 2; NRC Docket Nos. 50-313 and
50-368; Renewed Facility Operating License Nos. DPR-51
and NPF-6
08/30/2022
0CAN092201
Supplement to License Amendment Request for Approval of
Changes to the Emergency Plan Staffing Requirements;
Arkansas Nuclear One - Units 1 and 2; NRC Docket Nos.
50-313 and 50-368; Renewed Facility Operating License
09/29/2022
0CAN092301
Emergency Plan Implementing Procedure Revision,
Arkansas Nuclear One - Units 1 and 2; NRC Docket Nos.
50-313, 50-368, and 72-13; Renewed Facility Operating
09/05/2023
0CAN102301
Arkansas Nuclear One (ANO) Evacuation Time Estimate
(ETE) Study; Arkansas Nuclear One - Units 1 and 2; NRC
Docket Nos. 50-313, 50-368, and 72-13; Renewed Facility
Operating License Nos. DPR-51 and NPF-6
10/04/2023
0CAN102302
Arkansas Nuclear One (ANO) Emergency Plan Revision 49
and Emergency Plan On-Shift Staffing Analysis Revision 3;
Arkansas Nuclear One - Units 1 and 2; NRC Docket Nos.
50-313, 50-368, and 72-13; Renewed Facility Operating
10/11/2023
Procedures
Emergency Planning 10CFR50.54(q) Review Program
Corrective Action
Documents
CR-ANO-
C-2024-00559, C-2024-01282, C-2024-01283, C-2024-
284, C-2024-01288, C-2024-01292, C-2024-01294
OP-1003.010
EAL Unit 1 Wall Chart
OP-1903.010
Emergency Action Level Classification
Procedures
OP-1903.11
Emergency Response/Notifications
Corrective Action
Documents
CR-ANO-
C-2023-00759, C-2023-02869, C-2023-03166, C-2023-
03168, C-2023-03206, C-2023-03577, C-2023-03878, C-
24-00763, C-2024-01421, C-2024-01423, C-2024-01425,
C-2024-01427, C-2024-01432, C-2024-01433, C-2024-
01449
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Management Debrief, 8/20/2024 ANO NRC/FEMA
Graded/Evaluated Exercise
9/24/2024
1903.011
Emergency Response/Notifications
1903.030
Evacuation
1903.080
Emergency Operations Facility (EOF) Activation
1903.081
Technical Support Center Activation
1904.002
Offsite Dose Projections
1905.002
Offsite Emergency Monitoring
1905.004
EOF Radiological Controls
Drills and Exercises
Hostile Action Based Drills & Exercises
Emergency Planning Critiques
Emergency Operations Facility (EOF) Operations
Technical Support Center Operations
Procedures
Alternate EOF Emergency Response Facility Walkthrough
Work Orders
WO 54085373-01, 54137482
0CAN012102
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
01/20/2021
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
06/07/2022
0CAN062401
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
06/13/2024
Miscellaneous
0CAN071401
Emergency Plan Full Participation Exercise Drill Scenario;
Arkansas Nuclear One - Units 1 and 2; Docket Nos. 50-313
and 50-368; License Nos. DPR-51 and NPF-6
07/14/2014
OP-1903-011
Emergency Response/Notifications
Procedures
OP-1903.010
Emergency Action Level Classification
Calibration
Calibration of the "FASTSCAN 1" WBC System
04/05/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calibration of the MIRION FASTSCAN WBC System
04/22/2024
1601.488 - AMS-
043
Eberline Model AMS-4 Beta Particulate Air Monitor
Calibration
04/10/2024
1601.488 AMS-
2
Eberline Model AMS-4 Beta Particulate Air Monitor
Calibration
03/29/2023
23-B2.28-
CALDAT-00356
Portable Instrumentation Calibration Data Sheet
01/18/2023
23-B2.28-
CALDAT-01676
Portable Instrumentation Calibration Data Sheet
04/04/2023
23-B2.28-
CALDAT-02322
CHP-ARM112
Portable Instrumentation Calibration Data Sheet
07/03/2023
23-B2.28-
CALDAT-02691
Portable Instrument Calibration Data Sheet CHP-CR-179
08/02/2023
23-B2.28-
CALDAT-02795
Portable Instrumentation Calibration Data Sheet
08/09/2023
23-B2.28-
CALDAT-04828
Portable Instrumentation Calibration Data Sheet
2/11/2023
23-B2.28-
CALDAT-04872
CHP-DR-884
Portable Calibration Instrumentation Calibration Data Sheet
2/12/2023
24-B2.28-
CALDAT-00449
Portable Instrumentation Calibration Data Sheet
01/18/2024
24-B2.28-
CALDAT-01212
CHP-DR-346
Portable Instrumentation Calibration Data Sheet
03/04/2024
24-B2.28-
CALLDAT-02139
CHP-ARM070
Portable Instrumentation Calibration Data Sheet
04/25/2024
2304.151
Channel Functional Test of Fuel Handling Area 2RX-9830
(SPING 7)
07/11/2024
EN-RP-312 GEM-
006
Operation and Calibration of the Canberra GEM-5
01/25/2024
Records
EN-RP-312 GEM-
Operation and Calibration of the Canberra GEM-5
01/26/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
006
Operation and Calibration of the ARGOS-5AB Personnel
Contamination Monitor
07/25/2023
ARGOS-004
Operation and Calibration of the ARGOS-5AB Personnel
Contamination Monitor
01/31/2024
Cronos-001
Operation and Calibration of the CRONOS Contamination
Monitor
07/18/2023
Corrective Action
Documents
CR-ANO-
1-2023-01477, 1-2024-00059, 2-2022-01355, 2-2022-02113,
2-2023-00268, 2-2023-00269, 2-2023-00403, 2-2023-01468,
2-2023-01808, 2-2023-02805, 2-2023-02806, 2-2023-02872,
2-2023-02876, 2-2023-02884, 2-2023-02960, 2-2024-00035,
2-2024-00071, 2-2024-00143, 2-2024-00279, 2-2024-00362,
2-2024-00409, 2-2024-00437, 2-2024-00572, 2-2024-00621
Laboratory Analytical Quality Control
Source Checking of Radiation Protection Instrumentation
Operation and Calibration of the Canberra GEM-5
Operation and Calibration of the CRONOS Contamination
Monitor
EN-RP-317-04
Calibration of Portable Area Radiation Monitors
EN-RP-317-05
Calibration of Extendable Dose Rate Instruments
EN-RP-317-06
Calibration of MIRION RDS-31
EN-RP-317-07
Calibration of Portable Count Rate Instruments
EN-RP-317-10
Calibration of Portable Dose Rate Instruments
OP-1601.488
Eberline Model AMS-4 Beta Particulate Air Monitor
Calibration
OP-1903.010
Emergency Action Level Classification
Procedures
OP-2304.006
Unit 2 Gaseous Process Radiation Monitoring System
Calibration
OP-1304.027
Unit 1 Effluent Process Radiation Monitor Calibration
07/21/2022
Work Orders
OP-1304.138
Unit 1 Calibration of Radwaste Area Monitor RX-9825
(SPING 2)
2/23/2023
Corrective Action
Documents
CR-ANO-
C-2022-01794, 2-2023-01079, C-2023-00086, C-2023-
00151, C-2023-000197, C-2023-03548, C-2023-03550, C-
23-03990, C-2023-04087
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Resulting from
Inspection
CR-
ANO-C-2024-01166, HQN-2024-00754
22 NST
National Source Tracking Annual Inventory Reconciliation
Report
01/12/2022
23 NST
National Source Tracking Annual Inventory Reconciliation
Report
01/04/2023
21-08936-1
21 Dry Active Waste
01/31/2022
2-01658mu-f.3
22 Unit I Secondary Resin
03/14/2022
2-02911
22 Unit 2 Secondary Resin
05/03/2022
2-07076
22 Dry Active Waste
01/11/2023
23-03272
23 Dry Active Waste
05/24/2023
Radioactive Material Category 1 and 2 Accountability from
July 10, 2023, through July 1, 2024
07/02/2024
WO-53029674_1
Semi Annual Leak Test of Sealed Sources
10/12/2023
Miscellaneous
WO-54039565_1
Semi Annual Leak Test of Sealed Sources
04/09/2024
Source Control
Radioactive Waste Management
Radioactive Shipping Procedure
Procedures
Integrated Transportation Security Plan
ANO-22-05-
00112
Steam Generator Mausoleum
05/10/2022
ANO-24-03-
00179
Cask Transfer Facility
03/25/2024
00933
TAB Building
05/28/2024
ANO-24-05-
00179
Low Level Rad Waste
05/03/2024
ANO-24-05-
261
Old Rad Waste Building
05/04/2024
Radiation
Surveys
ANO-24-05-
00913
CTF Dry Fuel Pad
05/22/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ANO-24-05-
00914
Dry Fuel Pad
05/22/2024
ANO-24-05-
00931
Steam Generator Mausoleum
05/28/2024
LO-ALO-2023-
00038
Radiation Inspection - RP - Radiation Monitoring
Instrumentation, Radioactive Solid Waste Processing &
Radioactive Material Handling Storage, & Transportation
01/10/2024
QA-14/15-2023-
ANO-1
23 QA Audit Report of Radiation Protection and Radwaste
09/11/2023
WT-WTANO-
2019-00003 CA-
00159
CFR 37 ANNUAL REVIEW for 2022
2/15/2022
Self-Assessments
WT-WTANO-
2019-00003 CA-
00174
CFR 37 ANNUAL REVIEW for 2023
01/04/2024
RSR-22-058
SEDS equipment in a 10-foot Sea Land as SCO-II
09/20/2022
RSR-22-089
Mechanical Filters in a High Integrity Container /Cask
shipped as LSA-II
2/08/2022
RSR-23-046
Unit 2 'B' RCP Seal, Type A
04/27/2023
Shipping Records
RSR-23-080
Mechanical Filters in a High Integrity Container/Cask as
LSA-II
09/14/2023
ANO Dynamic Exam Scenario SES-1-024
11/29/2023
ANO Dynamic Exam Scenario SES-1-025A
01/25/2024
ANO Dynamic Exam Scenario SES-2-027
01/09/2024
ANO Dynamic Exam Scenario SES-2-EAL2
04/17/2024
ANS Test Data from 3Q2023 - 2Q2024
Miscellaneous
ERO Drill Participation Data 2Q2023-3Q2024
ANO 2023 Green Team 3rd Quarter PI Drill Report
08/24/2023
ANO 2023 Green Team 3rd Quarter PI Drill Report
03/15/2024
ANO 2024 Green Team 1st Quarter Drill Report
01/17/2024
ANO Alert and Notification System Design Report
EN-FAP-EP-005
Emergency Preparedness Performance Indicators
71151
Procedures
Emergency Planning Performance Indicators Desk Guide
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-ANO-
1-2015-02032, 1-2023-00277, 1-2024-01020, 1-2024-01328,
Radiological Groundwater Protection Program
Procedures
OP-1102.015
Filling and Draining the Fuel Transfer Canal
Work Orders
Corrective Action
Documents
CR-ANO-
1-2024-00923, 1-2024-00925, 1-2024-00966, 1-2024-01364