IR 05000368/2006008
| ML063550454 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 12/20/2006 |
| From: | David Proulx NRC/RGN-IV/DRP/RPB-E |
| To: | Forbes J Entergy Operations |
| References | |
| IR-06-008 | |
| Download: ML063550454 (20) | |
Text
December 20, 2006
SUBJECT:
ARKANSAS NUCLEAR ONE, UNIT 2 - NRC PRESSURIZER REPLACEMENT INSPECTION REPORT 05000368/2006008
Dear Mr. Forbes:
On November 9, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Arkansas Nuclear One, Unit 2, facility. This inspection covered activities associated with the replacement of the pressurizer in Unit 2. No inspection of Unit 1 was performed under this report number. The enclosed report documents the inspection findings, which were discussed on November 9, 2006, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.
Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel.
Based on the results of this inspection, no findings of significance were identified.
In accordance with 10 CFR 2.390 of the NRC's Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
David L. Proulx, Chief Project Branch E Division of Reactor Projects Docket: 50-368 License: NPF-6
Entergy Operations, Inc.
-2-
Enclosure:
NRC Inspection Report 05000368/2006008 w/Attachments:
1. Supplemental Information 2. Security Related Information
REGION IV==
Dockets:
50-368 Licenses:
NPF-6 Report:
05000368/2006008 Licensee:
Entergy Operations, Inc.
Facility:
Arkansas Nuclear One, Unit 2 Location:
Junction of Hwy. 64W and Hwy. 333 South Russellville, Arkansas Dates:
August 24 through November 9, 2006 Inspectors:
R. Deese, Senior Resident Inspector L. Carson II, Senior Health Physicist E. Crowe, Resident Inspector J. Kirkland, Project Engineer D. Livermore, Senior Project Engineer C. Paulk, Senior Reactor Inspector C. Young, Resident Inspector Accompanying Personnel:
S. Makor, Reactor Inspector Approved By:
David L. Proulx, Chief, Project Branch E Division of Reactor Projects
Enclosure-2-
SUMMARY OF FINDINGS
IR 05000368/2006008; 08/24/06 - 11/09/06; Arkansas Nuclear One, Unit 2; Integrated Resident and Regional Report of Pressurizer Replacement Activities.
This report covered a 3-month period of supplemental inspection by resident and regional inspectors. No findings were identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, Significance Determination Process. Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management's review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
NRC-Identified and Self-Revealing Findings
None.
Licensee-Identified Violations
None.
REPORT DETAILS
Summary of Plant Status
Unit 2 began the inspection period at 100 percent rated thermal power and remained there until September 19, 2006, when the unit was shut down for refueling and to replace the pressurizer.
The unit was restarted on October 27, 2006, and achieved 66 percent rated thermal power on October 30, 2006. The unit was holding at 66 percent rated thermal power for physics testing when on October 30, 2006, a fire in a motor control center necessitated a plant shutdown. The unit was restarted on October 31, 2006, achieved 100 percent rated thermal power on November 1, 2006, and remained there for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R02 Evaluation of Changes, Tests, or Experiments
a. Inspection Scope
The inspectors reviewed the effectiveness of the licensees implementation of changes to the facility structures, systems, and components; risk-significant normal and emergency operating procedures; test programs; and the updated final safety analysis report in accordance with 10 CFR 50.59, "Changes, Tests, and Experiments." The inspectors reviewed the safety evaluations performed by the licensee dealing with the pressurizer replacement. The evaluations were reviewed to verify that licensee personnel had appropriately considered the conditions under which the licensee may make changes to the facility or procedures or conduct tests or experiments without prior NRC approval. Procedures, evaluations, screenings, and applicability determinations reviewed are listed in the attachment to this report. Additional observations will be documented in Section 1R02 of NRC Inspection Report 05000313/05000368-2006005.
b. Findings
No findings of significance were identified.
1R08 Inservice Inspection Activities
a. Inspection Scope
The inspectors verified that observed examinations were performed in accordance with the specific site procedures and the applicable American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) requirements. During review of examinations, the inspectors verified that appropriate nondestructive examination procedures were used, examinations and conditions were as specified in the procedure, and test instrumentation or equipment was properly calibrated and within the allowable calibration period. The inspectors also verified the nondestructive examination certifications of the personnel who performed volumetric examinations. Finally, the inspectors observed that indications identified during the radiographic examinations were dispositioned in accordance with the ASME-qualified nondestructive examination procedures used to perform the examinations. Additional observations will be documented in Section 1R02 of NRC Inspection Report 05000313/05000368-2006005.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
Risk Assessment and Management of Risk The inspectors reviewed the assessment activities listed below to verify:
- (1) performance of risk assessments when required by 10 CFR 50.65 (a)(4) and licensee procedures prior to changes in plant configuration for maintenance activities and plant operations;
- (2) the accuracy, adequacy, and completeness of the information considered in the risk assessment;
- (3) that the licensee recognizes, and/or enters as applicable, the appropriate licensee-established risk category according to the risk assessment results and licensee procedures; and
- (4) that the licensee identified and corrected problems related to maintenance risk assessments. Additional observations will be documented in Section 1R13 of NRC Inspection Report 05000313/05000368-2006005.
- August 24 through October 27, 2006, construction of the temporary rail system through the containment equipment hatch
- August 24 through October 27, 2006, reviewed procedures and plans for crane operation near common systems
- August 24 through October 27, 2006, evaluated controls and plans to minimize any adverse impact on Unit 1 and common systems
- August 24 through October 27, 2006, transport of the removed pressurizer into the containment building and transport of the replacement pressurizer offsite
b. Findings
No findings of significance were identified.
1R17 Permanent Plant Modifications
a. Inspection Scope
The inspectors reviewed key affected parameters associated with energy needs, materials/replacement components, timing, heat removal, control signals, equipment protection from hazards, operations, flowpaths, pressure boundary, ventilation boundary, structural, process medium properties, licensing basis, and failure modes for modifications associated with the replacement pressurizer. The inspectors verified that:
- (1) modification preparation, staging, and implementation does not impair emergency/abnormal operating procedure actions, key safety functions, or operator response to loss of key safety functions;
- (2) postmodification testing will maintain the plant in a safe configuration during testing by verifying that unintended system interactions will not occur, structures, systems, and components (SSCs) performance characteristics still meet the design basis, the appropriateness of modification design assumptions, and the modification test acceptance criteria has been met; and
- (3) the licensee has identified and implemented appropriate corrective actions associated with permanent plant modifications. Additional observations will be documented in Section 1R17 of NRC Inspection Report 05000313/05000368-2006005.
b. Findings
No findings of significance were identified.
1R20 Refueling and Outage Activities
a. Inspection Scope
The inspectors reviewed and observed selected portions of the following risk significant refueling items or outage activities to verify defense in depth commensurate with the outage risk control plan and compliance with the Technical Specifications:
- (1) the risk control plan;
- (2) tagging/clearance activities;
- (3) reactor coolant system (RCS)instrumentation;
- (4) electrical power;
- (5) decay heat removal;
- (6) spent fuel pool cooling;
- (7) inventory control;
- (8) reactivity control;
- (9) containment closure;
- (10) reduced inventory or midloop conditions;
- (11) refueling activities;
- (12) heatup and cooldown activities; and
- (13) licensee identification and implementation of appropriate corrective actions associated with refueling, outage, and replacement activities. Additional observations will be documented in Section 1R17 of NRC Inspection Report 05000313/05000368-2006005.
b. Findings
No findings of significance were identified.
1R23 Temporary Plant Modifications
a. Inspection Scope
For the temporary modifications listed below, the inspectors reviewed the Final Safety Analysis Report (FSAR), plant drawings, procedure requirements, and Technical Specifications to ensure that the four temporary modifications listed below were properly implemented. The inspectors:
- (1) verified that the modification did not have an affect on system operability/availability,
- (2) verified that the installation was consistent with the modification documents,
- (3) ensured that the postinstallation test results were satisfactory and that the impact of the temporary modification on permanently installed SSCs were supported by the test,
- (4) verified that the modifications were identified on control room drawings and that appropriate identification tags were placed on the affected drawings, and
- (5) verified that appropriate safety evaluations were completed.
The inspectors verified the licensee identified and implemented any needed corrective actions associated with temporary modifications.
- September 19 - October 27, 2006, pressurizer removal and replacement
- September 19 - October 27, 2006, lifting and rigging preparations
b. Findings
No findings of significance were identified.
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety
2OS1 Access Control To Radiologically Significant Areas (71121.01)
a. Inspection Scope
This area was inspected to assess the licensees performance in implementing physical and administrative controls for airborne radioactivity areas, radiation areas, high radiation areas, and worker adherence to these controls with respect to the pressurizer replacement activities. The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensees procedures required by technical specifications as criteria for determining compliance. During the inspection, the inspectors interviewed the radiation protection manager, radiation protection supervisors, and radiation workers. The inspectors performed independent radiation dose rate measurements and reviewed the following items:
- Controls (surveys, posting, and barricades) of radiation, high radiation, or airborne radioactivity areas
- Radiation work permits, procedures, engineering controls, and air sampler locations
- Conformity of electronic personal dosimeter alarm set points with survey indications and plant policy; workers knowledge of required actions when their electronic personnel dosimeter noticeably malfunctions or alarms
- Barrier integrity and performance of engineering controls in airborne radioactivity areas
- Adequacy of the licensees internal dose assessment for any actual internal exposure greater than 50 millirem Committed Effective Dose Equivalent
- Self-assessments related to the access control program since the last inspection; there were no audits, licensee event reports, and special reports documented
- Corrective action documents related to access controls
- Licensee actions in cases of repetitive deficiencies or significant individual deficiencies
- Radiation work permit briefings and worker instructions
- Adequacy of radiological controls such as, required surveys, radiation protection job coverage, and contamination controls during job performance
- Dosimetry placement in high radiation work areas with significant dose rate gradients
- Changes in licensee procedural controls of high dose rate - high radiation areas and very high radiation areas
- Posting and locking of entrances to all accessible high dose rate - high radiation areas and very high radiation areas
- Radiation worker and radiation protection technician performance with respect to radiation protection work requirements The sample size for this inspection will be counted as part of NRC Inspection Report 05000313/05000368-2006005.
b. Findings
No findings of significance were identified.
2OS2 ALARA Planning and Controls (71121.02)
a. Inspection Scope
The inspectors assessed licensee performance with respect to maintaining individual and collective radiation exposures as low as is reasonably achievable (ALARA) during the pressurizer replacement. The inspectors used the requirements in 10 CFR Part 20 and the licensees procedures required by technical specifications as criteria for determining compliance. The inspectors interviewed licensee personnel and reviewed:
- Pressurizer replacement work activities scheduled during the inspection period and associated work activity exposure estimates which were likely to result in the highest personnel collective exposures
- Site specific ALARA procedures
- ALARA work activity evaluations, exposure estimates, and exposure mitigation requirements
- Intended versus actual work activity doses and the reasons for any inconsistencies
- Interfaces between operations, radiation protection, maintenance, maintenance planning, scheduling and engineering groups
- Integration of ALARA requirements into work procedure and radiation work permit documents
- Person-hour estimates provided by maintenance planning and other groups to the radiation protection group with the actual work activity time requirements
- Shielding requests and dose/benefit analyses
- Dose rate reduction activities in work planning
- Method for adjusting exposure estimates, or re-planning work, when unexpected changes in scope or emergent work were encountered
- Exposure tracking system
- Use of engineering controls to achieve dose reductions and dose reduction benefits afforded by shielding
- Workers use of the low dose waiting areas
- First-line job supervisors contribution to ensuring work activities are conducted in a dose efficient manner
- Exposures of individuals from selected work groups
- Source-term control strategy or justifications for not pursuing such exposure reduction initiatives
- Radiation worker and radiation protection technician performance during work activities in radiation areas, airborne radioactivity areas, or high radiation areas
- Self-assessments related to the ALARA program since the last inspection; there were no audits and special reports documented The sample size for this inspection will be counted as part of NRC Inspection Report 05000313/05000368-2006005.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA2 Identification and Resolution of Problems
Pressurizer Replacement Inspection (50003)
a. Inspection Scope
The inspectors reviewed the daily condition report summaries and nonconformance reports issued during the pressurizer replacement project for risk-significant issues to determine if the licensee was properly implementing the corrective action program. The inspectors verified that the licensee identified, evaluated, corrected, and trended in accordance with the program requirements. In addition, the inspectors reviewed the licensees actions to identify and correct lessons learned from the Unit 1 steam generator and reactor vessel head replacement project and the Unit 2 steam generator replacement project.
b. Findings
No findings of significance were identified.
4OA5 Other Activities
Pressurizer Replacement Inspection (50003) Design and Planning Inspections
a. Inspection Scope
The inspectors used the guidance in Inspection Procedure 50003, Pressurizer Replacement Inspection, to perform the following pressurizer design and planning inspection activities:
Engineering and Technical Support Inspections to review engineering and technical support activities were performed prior to and during the pressurizer replacement outage by resident and regional office-based specialist inspectors. The results of the inspection are documented in Sections 1R17 and 1R23. NRC Inspection Report 05000313/05000368-2006005, Sections 1R02,
1R08, and 1R17, will document additional activities that were performed as part of this review.
This review verified that selected design changes and modifications to SSCs described in the FSAR were reviewed in accordance with 10 CFR 50.59. Additionally, key design aspects and modifications associated with the pressurizer replacement were also reviewed.
Lifting and Rigging Inspections to review engineering design, modification, and analysis associated with pressurizer lifting and rigging activities were performed by resident and regional inspectors. This included:
- (1) crane and rigging equipment,
- (2) pressurizer component drop analysis,
- (3) safe load paths, and
- (4) load lay-down areas.
Radiation Protection The review of radiation protection program controls, planning, and preparation in:
- (1) ALARA planning,
- (2) dose estimates and tracking,
- (3) exposure and contamination controls,
- (4) radioactive material management,
- (5) radiological work plans and controls,
- (6) emergency contingencies, and
- (7) project staffing and training plans is scheduled to be completed as part of the upcoming ALARA planning and controls inspection and documented in an upcoming integrated resident inspection report. Part of these activities were performed and are documented in Section 2OS1. Additional activities will be documented in NRC Inspection Report 05000313/05000368-2006005, Section 2OS1.
Additional Activities Additional activities performed are documented in Attachment 2 which is designated and marked as Security Related Information.
b. Findings
No findings of significance were identified.
Pressurizer Removal and Replacement Inspections
a. Inspection Scope
The inspectors used the guidance in Inspection Procedure 50003 to perform the following pressurizer removal and replacement inspection activities:
Welding and Nondestructive Examination Activities Inspections were conducted to review welding and nondestructive examination activities including:
- (1) special procedures,
- (2) training and qualifications,
- (3) radiography results and work packages, and
- (4) completion of preservice NDE requirements for welds. This inspection was performed as part of Inspection Procedure 71111.08, Inservice Inspection Activities. Additional observations will be documented in Section 1R08 of NRC Inspection Report 05000313/05000368-2006005.
Lifting and Rigging Inspections were conducted to review the preparations and procedures for rigging and heavy lifting including crane and rigging inspections, testing, equipment modifications, lay-down area preparations, and training for the following activities:
- Area preparation for the outside systems
- Pressurizer lifting device
- Upending device
- Old pressurizer removal
- New pressurizer placement
- Transport of old pressurizer offsite Major Structural Modifications The inspectors observed the implementation and reviewed documentation related to structural modifications to facilitate pressurizer replacement, including the structural supports for the pressurizer, the temporary RCS piping structural supports, and all attached piping during all phases of removal and installation of the pressurizer.
Outage Operating Conditions The inspectors observed the establishment of operating conditions, including
- (1) defueling;
- (2) RCS draindown;
- (3) system isolation;
- (4) safety tagging;
- (5) radiation protection controls;
- (6) controls for excluding foreign material; and
- (7) installation, use, and removal of temporary services. Section 1R20 contains additional activities that were performed. NRC Inspection Reports 05000313/05000368-2006004 and 05000313/05000368-2006005, Section 1R20, will also documents activities performed during the pressurizer replacement outage.
Storage of Removed Pressurizer The inspectors observed the transport, storage, and radiological surveys of the removed pressurizer prior to shipment offsite. The radiological safety plans were also reviewed.
b. Findings
No findings of significance were identified.
Postinstallation Verification and Testing Inspections
a. Inspection Scope
The inspectors used the guidance in Inspection Procedure 50003 to perform the following postinstallation verification and testing inspection activities. Selective inspections were performed on the following areas:
- (1) containment testing,
- (2) licensees postinstallation inspections and verifications program and its implementation,
- (3) conduct of RCS leakage testing and review of test results,
- (4) calibration and testing of instrumentation affected by pressurizer replacement,
- (5) procedures required equipment performance testing to confirm the design and to establish baseline measurements,
- (6) preservice inspection of new welds, and (7)pressurizer thermal and hydraulic performance.
b. Findings
No findings of significance were identified.
4OA6 Meetings, Including Exit
On October 6, 2006, the inspectors presented the Occupational Radiation Safety inspection results regarding the pressurizer replacement to Mr. T. Mitchell, General Manager, and other members of his staff who acknowledged the findings. The inspectors confirmed that proprietary information was not provided or examined during the inspection.
The engineering inspectors presented the results of the inservice inspection and welding review to Mr. J. Kowalewski, Director, Engineering, on October 10, 2006.
Mr. Kowalewski acknowledged the inspection findings. The inspectors identified that they had not reviewed proprietary information The inspectors presented the inspection results to Mr. T. Mitchell, General Manager, and other members of the licensee's management staff on November 9, 2006. The licensee acknowledged the findings presented. The inspectors noted that while proprietary information was reviewed, none would be included in this report.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- J. Bacquet, ALARA Supervisor
- R. Barnes, Manager, Planning, Scheduling, and Outages
- B. Berryman, Manager, Operations Unit 1
- J. Browning, Manager, Operations Unit 2
- S. Cotton, Manager, Training
- B. Daiber, Supervisor, Systems Engineering
- F. Daubenmeyer, Project Manager
- J. Eichenberger, Manager, Corrective Actions and Assessments
- J. Forbes, Vice President, Operations
- J. Giles, Manager, Technical Support
- M. Ginsberg, Supervisor, Engineering Programs and Components
- A. Hawkins, Licensing Specialist
- J. Hoffpauir, Manager, Maintenance
- R. Holeyfield, Manager, Emergency Planning
- M. Huff, Supervisor, Project Engineering
- D. James, Manager, Licensing
- W. James, Manager, Engineering Projects
- J. Kowalewski, Director, Engineering
- T. Marlow, Director, Nuclear Safety Assurance
- J. Miller, Jr., Manager, System Engineering
- T. Mitchell, General Manager, Plant Operations
- D. Moore, Manager, Radiation Protection
- C. Reasoner, Manager, Engineering Programs and Components
- M. Ruder, Corrective Actions and Assessments
- C. Tyrone, Manager, Quality Assurance
- F. Van Buskirk, Licensing Specialist
- P. Williams, Supervisor, Systems Engineering
- M. Woodby, Manager, Design Engineering
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
None
Closed
None
Discussed
None