Text

NRC Inspection Report 05000313/2016003 and 05000368/2016003 and Exercise of Enforcement Discretion
	ML16307A436
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/02/2016
From:	O'Keefe N; NRC/RGN-IV/DRP/RPB-E
To:	Richard Anderson; Entergy Operations
	O'Keefe C
References
	EA-16-143 IR 2016003
	Download: ML16307A436 (72)
	v • d • e

UNITED STATES ber 2, 2016

SUBJECT:

ARKANSAS NUCLEAR ONE - NRC INSPECTION REPORT 05000313/2016003 AND 05000368/2016003 AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Anderson:

On September 30, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Arkansas Nuclear One facility, Units 1 and 2. On October 6, 2016, the NRC inspectors discussed the results of this inspection with you and other members of your staff.

Inspectors documented the results of this inspection in the enclosed inspection report.

No NRC-identified or self-revealing findings were identified during this inspection.

However, inspectors documented licensee-identified violations which were determined to be of very low safety significance. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC Enforcement Policy.

If you contest the violations or significance of these NCVs, 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, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at Arkansas Nuclear One.

Also, a violation of the licensees current site-specific licensing basis for tornado-generated missile protection was identified. Because this violation was identified during the discretion period discussed in Enforcement Guidance Memorandum 15-002, Enforcement Discretion for Tornado Missile Protection Noncompliance, and because the licensee implemented compensatory measures, the NRC is exercising enforcement discretion by not issuing an enforcement action for the violation and allowing continued reactor operation. (EA-16-143) In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access and Management 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/

Neil OKeefe, Branch Chief Project Branch E Division of Reactor Projects Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6

Enclosure:

Inspection Report 05000313/2016003 and 05000368/2016003 w/ Attachments:

1. Supplemental Information 2. DRS Request for Information 3. Additional Information Regarding Tornado-Generated Missile Protection Noncompliances

REGION IV==

Docket: 05000313; 05000368 License: DPR-51; NPF-6 Report: 05000313/2016003; 05000368/2016003 Licensee: Entergy Operations, Inc.

Facility: Arkansas Nuclear One, Units 1 and 2 Location: Junction of Highway 64 West and Highway 333 South Russellville, Arkansas Dates: July 1 through September 30, 2016 Inspectors: B. Tindell, Senior Resident Inspector A. Barrett, Resident Inspector M. Tobin, Resident Inspector R. Alexander, Senior Project Engineer B. Baca, Health Physicist M. Bloodgood, Operations Engineer L. Carson II, Sr. Health Physicist J. Choate, Project Engineer B. Correll, Project Engineer J. Dixon, Senior Project Engineer P. Elkmann, Senior Emergency Preparedness Inspector N. Greene, PhD, Health Physicist G. Guerra, CHP, Emergency Preparedness Inspector S Hedger, Operations Engineer J. ODonnell, CHP, Health Physicist N. Okonkwo, Reactor Inspector C. Osterholtz, Senior Operations Engineer M. Phalen, Sr. Health Physicist C. Steely, Operations Engineer Approved Neil OKeefe By: Chief, Project Branch E Division of Reactor Projects-1- Enclosure

SUMMARY

IR 05000313/2016003; 05000368/2016003; 07/01/2016 - 09/30/2016; Arkansas Nuclear One,

Units 1 and 2, Integrated Inspection Report.

The inspection activities described in this report were performed between July 1 and September 30, 2016, by the resident inspectors at Arkansas Nuclear One and inspectors from the NRCs Region IV office and other NRC offices. NRC inspectors documented three licensee-identified violations of very low safety significance in this report. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects within the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

No findings were identified.

Licensee-Identified Violations

Violations of very low safety significance that were identified by the licensee have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. These violations and associated corrective action tracking numbers are listed in Section 4OA7 of this report.

PLANT STATUS

Unit 1 began the period at 100 percent power. On September 5, 2016, the unit began coast-down operations, with operators slowly lowering reactor power due to expected fuel burnup at end of core life. On September 23, 2016, the licensee shut down the unit for a planned refueling outage a week later than originally planned, which allowed the plant staff to focus on repairing emergency diesel generator A in Unit 2. The unit remained shut down through the end of the inspection period.

Unit 2 began the period at 100 percent power. On August 19, 2016, the station experienced increased debris buildup at the plant intake structure. Maintenance personnel manually cleaned the prescreens, which resulted in debris entering one service water strainer. Unit 2 operators aligned the emergency cooling pond to the service water pump suction and maintenance personnel manually cleaned the straner. On September 16, 2016, the emergency diesel generator A inboard bearing failed due to overheating caused by lack of lubrication during a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> surveillance. On September 28, 2016, the licensee shut down the unit prior to the expiration of the inoperable diesels technical specification action statement. The unit remained shut down through the end of the inspection period.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

.1 Summer Readiness for Offsite and Alternate AC Power Systems

a. Inspection Scope

On July 21, 2016, the inspectors completed an inspection of the stations off-site and alternate-ac power systems. The inspectors inspected the material condition of these systems, including transformers and other switchyard equipment to verify that plant features and procedures were appropriate for operation and continued availability of off-site and alternate-ac power systems. The inspectors reviewed outstanding work orders and open condition reports for these systems. The inspectors performed a walk down of the transformer yard to observe the material condition of equipment providing off-site power sources. The inspectors verified that the licensees procedures included appropriate measures to monitor and maintain availability and reliability of the off-site and alternate-ac power systems.

These activities constituted one sample of summer readiness of off-site and alternate-ac power systems, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

.2 Readiness to Cope with External Flooding

a. Inspection Scope

On August 9, 2016, the inspectors completed an inspection of the stations readiness to cope with external flooding. After reviewing the licensees flooding analysis, the inspectors chose two plant areas that were susceptible to flooding:

Unit 1, turbine building drain piping in auxiliary building basement

Unit 2, turbine building drain piping in auxiliary building basement The inspectors reviewed plant design features and licensee procedures for coping with flooding. The inspectors performed a walk down of the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether credited operator actions could be successfully accomplished.

These activities constituted one sample of readiness to cope with external flooding, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Main article: IP 71111.04

.1 Partial Walk-Down

a. Inspection Scope

The inspectors performed partial system walk-downs of the following risk-significant systems:

July 19, 2016, Units 1 and 2, electric firewater pump and temporary firewater pump while diesel firewater pump was out of service for maintenance

August 31, 2016, Unit 2, service water pump B and loop 1 while service water pump A was out of service for maintenance

September 19, 2016, Unit 2, emergency diesel generator B while diesel A was out of service for emergent maintenance

September 22, 2016, Unit 1, charging pump lineup after charging pump B was realigned after being out of service for maintenance

September 29, 2016, Unit 1, decay heat removal system train A while decay heat in service but inoperable due to cracked weld The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems or trains were correctly aligned for the existing plant configuration.

These activities constituted five partial system walk-down samples as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

.2 Complete Walk-Down

a. Inspection Scope

On September 22, 2016, the inspectors performed a complete system walk-down inspection of the Unit 1 125 VDC distribution system. The inspectors reviewed the licensees procedures and system design information to determine the correct breaker and switch lineup for the existing plant configuration. The inspectors also reviewed outstanding work orders and condition reports for the system. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.

These activities constituted one complete system walk-down sample, as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1R05 Fire Protection

Main article: IP 71111.05

.1 Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on six plant areas important to safety:

August 5, 2015, Unit 1, Fire Area N, diesel driven fire pump room

August 19, 2016, Unit 1, Fire Zone 144-D, upper south electrical penetration room

August 22, 2016, Unit 1, Fire Zone 38-Y, emergency feedwater pump room area

September 2, 2016, Unit 1, Fire Zone 129-F, control room

September 2, 2016, Unit 2, Fire Zone 2199-G, control room

September 2, 2016, Unit 2, Fire Zone 2098-L, cable spreading room For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.

These activities constituted six quarterly inspection samples, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

.2 Annual Inspection

a. Inspection Scope

The inspectors completed their annual evaluation of the licensees fire brigade performance. This evaluation included observation of an unannounced fire brigade drill.

August 25, 2016, Unit 2, unannounced fire drill at hydrogen seal oil skid During this drill, the inspectors evaluated the capability of the fire brigade members, the leadership ability of the brigade leader, the brigades use of turnout gear and fire-fighting equipment, and the effectiveness of the fire brigades team operation. The inspectors also reviewed whether the licensees fire brigade met NRC requirements for training, dedicated size and membership, and equipment.

These activities constituted one annual inspection sample, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

Main article: IP 71111.06

a. Inspection Scope

On August 8, 2016, the inspectors completed an inspection of the stations ability to mitigate flooding due to internal causes. After reviewing the licensees flooding analysis, the inspectors chose the Unit 1 intake structure, which contains risk-significant structures, systems, and components (SSCs) that were susceptible to flooding.

The inspectors reviewed plant design features and licensee procedures for coping with internal flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether operator actions credited for flood mitigation could be successfully accomplished.

These activities constituted completion of one flood protection measures sample, as defined in Inspection Procedure 71111.06.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

Main article: IP 71111.07

a. Inspection Scope

On September 21, 2016, the inspectors completed an inspection of the readiness and availability of risk-significant heat exchangers. The inspectors reviewed the data from a performance test for the Unit 1 decay heat cooler A and verified the licensee used the industry standard periodic maintenance method outlined in EPRI NP-7552 for the decay heat cooler. Additionally, the inspectors walked down the heat exchanger to observe its material condition.

These activities constituted completion of one heat sink performance annual review sample, as defined in Inspection Procedure 71111.07.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

Main article: IP 71111.11

.1 Review of Licensed Operator Requalification

a. Inspection Scope

The inspectors observed simulator training for licensed operators. The inspectors assessed the performance of the operators and the evaluators critique of their performance. The inspectors also assessed the modeling and performance of the simulator during the requalification activities.

August 10, 2016, Unit 2, simulator training for operating crew

September 1, 2016, Unit 1, simulator training for operating crew These activities constituted completion of two quarterly licensed operator requalification program samples, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

The inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened activity and risk. The inspectors observed the operators performance of the following activities:

August 4, 2016, Unit 2, alternate ac diesel generator quarterly surveillance

August 8, 2016, Unit 1, post maintenance alignment and testing of the swing high pressure injection pump In addition, the inspectors assessed the operators adherence to plant procedures, including the conduct of operations procedure and other operations department policies.

These activities constituted completion of two quarterly licensed operator performance samples, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.3 Biennial Inspection

The licensed operator requalification program involves two training cycles that are conducted over a 2-year period. In the first cycle, the annual cycle, the operators administered an operating test consisting of job performance measures and simulator scenarios. In the second cycle, the biennial cycle, operators administered an operating test and a comprehensive written examination. During this inspection, Unit 1 was in the first part of the training cycle and Unit 2 was in the second part of the training cycle.

a. Inspection Scope

For Unit 1, inspectors observed portions of their 2016 operating test and 2015 comprehensive written examination. For Unit 2, inspectors observed portions of their 2016 operating test and comprehensive written examination. To assess the performance effectiveness of the licensed operator requalification program, the inspectors conducted personnel interviews; reviewed medical records of licensed operators for conformance to license conditions; reviewed the minutes of training review group meetings to assess the responsiveness of the licensed operator requalification program to incorporate the lessons learned from both plant and industry events; reviewed examination security measures, simulator fidelity, and existing logs of simulator deficiencies; and observed job performance measures and scenarios that were administered during the week of July 11, 2016. These observations allowed the inspectors to assess the licensees effectiveness in conducting the operating test to ensure operator mastery of the training program content.

The results of these examinations were reviewed to determine the effectiveness of the licensees appraisal of operator performance and to determine if feedback of performance analyses into the requalification training program was being accomplished.

The inspectors interviewed members of the training department and reviewed minutes of training review group meetings to assess the responsiveness of the licensed operator requalification program to incorporate the lessons learned from both plant and industry events. Examination results were also assessed to determine if they were consistent with the guidance contained in NUREG 1021, Operator Licensing Examination Standards for Power Reactors, Revision 10, and NRC Manual Chapter 0609, Appendix I, Licensed Operator Requalification Significance Determination Process.

Inspectors reviewed the operating test results of both units and the results of the Unit 2 comprehensive written examinations. On August 5 and 11, 2016, the licensee informed the lead inspectors of the following results respectively:

Unit 1:

55 total licensed operators

8 of 10 crews passed the simulator portion of the operating test

48 of 51 licensed operators passed the simulator portion of the operating test

51 of 51 licensed operators passed the job performance measure of the operating test Four licensed operators were not given a requalification examination since they are participating in the facilitys senior reactor upgrade training program and, therefore, are not required to be tested. All four individuals are restricted from any watch standing duties. The three individuals and two crews that failed their simulator scenarios were remediated, retested, and passed retake tests prior to returning to shift.

Unit 2:

52 total licensed operators

10 of 10 crews passed the simulator portion of the operating test

52 of 52 licensed operators passed the simulator portion of the operating test

52 of 52 licensed operators passed the job performance measure portion of the operating test

52 of 52 licensed operators passed the written examination The inspectors compared these results to NRC Inspection Manual Chapter 0609, Appendix I, Licensed Operator Requalification Significance Determination Process, values and determined that there were no findings based on these results.

The inspectors observed examination security measures in place during administration of the exams (including controls and content overlap) and reviewed any remedial training and re-examinations, if necessary. The inspectors also reviewed medical records of 12 licensed operators for conformance to license conditions and the licensees system for tracking qualifications and records of license reactivation for seven operators. In addition, the inspectors reviewed simulator performance for fidelity with the actual plant and the overall simulator program of maintenance, testing, and discrepancy correction.

The inspectors completed one inspection sample of the biennial licensed operator requalification program for Unit 1 and one inspection sample of the biennial licensed operator requalification program for Unit 2.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

Main article: IP 71111.12

a. Inspection Scope

The inspectors reviewed two instances of degraded performance or condition of safety-related SSCs:

August 18, 2016, Units 1 and 2, control room emergency chiller system review

September 6, 2016, Unit 2, high pressure safety injection, reviewed effectiveness of pressurization system corrective actions The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.

These activities constituted completion of two maintenance effectiveness samples, as defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

a. Inspection Scope

The inspectors reviewed five risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:

August 29, 2016, Unit 2, service water prescreen A and B cleaning

September 21, 2016, Unit 2, emergency diesel generator A out of service due to a bearing failure on September 16, 2016

September 23, 2016, Unit 1, refueling outage plan

September 26, 2016, Unit 1, equipment hatch emergency closure plan

September 28, 2016, Unit 2, unscheduled outage plan The inspectors verified that these risk assessments were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.

The inspectors also observed portions of three emergent work activities that had the potential to cause an initiating event and to affect the functional capability of mitigating systems.

July 26, 2016, Unit 2, control element drive mechanism control system undervoltage relay failure

September 22, 2016, Unit 2, emergency diesel generator A shaft rigging plan

September 30, 2016, Unit 1, decay heat system leak from train B instrument pipe The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected SSCs, and appropriately implemented compensatory measures.

These activities constituted completion of eight maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

Main article: IP 71111.15

.1 Operability Determinations

a. Inspection Scope

The inspectors reviewed five operability determinations that the licensee performed for degraded or nonconforming SSCs:

July 8, 2016, operability determination of Unit 2 emergency diesel generator fuel oil transfer pumps following pump start switch failure

August 8, 2016, operability determination of Unit 2 pressurizer level upper procedural operational limits

August 26, 2016, operability determination of Unit 1 emergency diesel generators for crankcase pressure trip susceptibility to tornado pressure effects

September 22, 2016, operability determination of Unit 1 tornado missile vulnerabilities in the upper south electrical penetration room, cable spreading room, controlled access area, and vital switchgear.

September 30, 2016, operability determination of Unit 1 decay heat system leak The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability of the degraded SSC.

The inspectors reviewed operator actions taken or planned to compensate for degraded or nonconforming conditions. The inspectors verified that the licensee effectively managed these operator workarounds to prevent adverse effects on the function of mitigating systems and to minimize their impact on the operators ability to implement abnormal and emergency operating procedures.

These activities constituted completion of five operability and functionality review samples, as defined in Inspection Procedure 71111.15.

b. Findings

No findings were identified.

.2 EA-16-143, Enforcement Discretion for Tornado-Generated Missile Protection

Noncompliances Description Appendix A to 10 CFR 50, General Design Criteria for Nuclear Power Plants, Criterion 2, Design Bases for Protection Against Natural Phenomena, states, in part, that SSCs important to safety shall be designed to withstand the effects of natural phenomena, such as tornadoes. Criterion 4, Environmental and Dynamic Effects Design Basis, states, in part, that SSCs important to safety shall be appropriately protected against dynamic effects including missiles which may result from events and conditions outside the nuclear power unit.

As part of their response to external flood boundary degradation, the licensee performed a review of external hazard protection at the site, which included protection against tornado-generated missiles required by the current licensing basis for each unit. During the review, on four separate occasions, the licensee identified plant areas containing safety-related SSCs that could be susceptible to tornado missiles:

Unit 1 Upper South Electrical Penetration Room

Unit 1 Cable Spreading Room

Unit 1 Controlled Access Area

Unit 1 Vital Switchgear In each case, the licensee identified low-probability scenarios where one or more tornado-generated missiles could penetrate doors, walls, and other building features that were not fully qualified, and subsequently damage equipment that was important to safety inside the affected rooms. Details about the date of discovery, affected SSCs, condition report numbers, compensatory actions taken by the licensee, notifications made to the NRC, and affected technical specification actions for each susceptible area are listed in Attachment 3 of this report.

Relevant Enforcement Discretion Policy On June 10, 2015, the NRC issued Enforcement Guidance Memorandum (EGM) 15-002, Enforcement Discretion for Tornado-Generated Missile Protection Noncompliance. (ML15111A269) The EGM referenced a bounding generic risk analysis performed by the NRC staff that concluded that tornado missile vulnerabilities pose a low risk significance to operating nuclear plants. Because of this, the EGM described the conditions under which the NRC staff may exercise enforcement discretion for noncompliances with the current licensing basis for tornado-generated missile protection. Specifically, if the licensee could not meet the technical specification required actions within the required completion time, the EGM allows the staff to exercise enforcement discretion provided the licensee implements initial compensatory measures prior to the expiration of the time allowed by the limiting condition for operation. The compensatory actions should provide additional protection such that the likelihood of tornado missile effects are lessened. The EGM then requires the licensee to implement more comprehensive compensatory measures within approximately 60 days of issue discovery. The compensatory measures must remain in place until permanent repairs are completed, or until the NRC dispositions the non-compliance in accordance with a method acceptable to the NRC such that discretion is no longer needed. In addition, the issue must be entered into the licensees corrective action program. Because EGM 15-002 listed Arkansas Nuclear One as a Group A plant, enforcement discretion will expire on June 10, 2018. However, the EGM did not provide for enforcement discretion for any related underlying technical violations; the EGM specifically requires that any associated underlying technical violations be assessed through the enforcement process.

Licensee Actions For each of the examples listed above, the licensee declared the affected systems inoperable and complied with the applicable technical specification action statement(s),initiated a condition report, invoked the enforcement discretion guidance, implemented prompt compensatory measures, and returned the SSCs to an operable status. The licensee instituted compensatory measures intended to reduce the likelihood of tornado missile effects that included developing actions to be taken if a tornado watch is predicted or issued for the area to ensure the operability or restore redundant equipment during severe weather, and actions to be taken if a tornado warning is issued, including pre-staging operators in safe, strategic locations to promptly implement mitigative actions, and verifying the readiness of equipment and procedures dedicated to the Diverse and Flexible Coping Strategy (FLEX). Other specific compensatory actions for the individual areas are listed in Attachment 3.

NRC Actions The inspectors review addressed the material issues in the plant, and whether the measures were implemented in accordance with the guidance in EGM 15-002. The inspectors also evaluated whether the measures would function as intended and were properly controlled. The inspectors verified through inspection that the EGM 15-002 criteria were met in each case. Therefore, the staff determined that it was appropriate to exercise enforcement discretion and not take enforcement action for the technical specification requirements listed in Attachment 3 of this report, provided the non-compliances are resolved by June 10, 2018 (EA-16-143).

The inspectors did not fully review the underlying circumstances that resulted in the technical specification violations. As stated in EGM 15-002, violations of other requirements which may have contributed to the technical specification violations will be evaluated independently of EGM implementation. The inspectors will verify restoration of compliance and assess the underlying circumstances in a follow-up inspection tracked under Licensee Event Reports 05000313/2016-002-00 and 05000313/2016-003-00, and any updates or additional licensee event reports that the licensee issues.

1R18 Plant Modifications

Main article: IP 71111.18

a. Inspection Scope

The inspectors reviewed four permanent plant modifications that affected risk-significant SSCs:

August 8, 2016, Unit 1, coupling replacement for high pressure injection pump B

August 26, 2016, Unit 1 and Unit 2, common feedwater system installation

September 6, 2016, Unit 1, reactor coolant system letdown heat exchanger replacement

September 20, 2016, Unit 2, install emergency diesel generator A shaft sleeve at inboard bearing following bearing damage The inspectors reviewed the design and implementation of the modifications. The inspectors verified that work activities involved in implementing the modifications did not adversely impact operator actions that may be required in response to an emergency or other unplanned event. The inspectors verified that post-modification testing was adequate to establish the operability or functionality of the SSCs as modified.

These activities constituted completion of four samples of permanent modifications, as defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

Main article: IP 71111.19

a. Inspection Scope

The inspectors reviewed four post-maintenance testing activities that affected risk-significant SSCs:

July 20, 2016, Unit 1, cable spreading room fire protection deluge valve clapper manual manipulation and reset following internals replacement

July 27, 2016, Units 1 and 2, diesel fire pump full flow test following engine overhaul

August 2, 2016, Unit 1, high pressure injection pump B test following coupling replacement

August 26, 2016, Unit 1, auxiliary building hatch seal smoke test following hatch removal and seal replacement The inspectors reviewed licensing- and design-basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.

These activities constituted completion of four post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

Main article: IP 71111.20

a. Inspection Scope

During the Unit 1 refueling outage and the Unit 2 unplanned outage, the inspectors evaluated the licensees outage activities. The inspectors verified that the licensee considered risk in developing and implementing the outage plan, appropriately managed personnel fatigue, and developed mitigation strategies for losses of key safety functions.

This verification included the following:

Review of the licensees outage plan prior to the outage

Review and verification of the licensees fatigue management activities

Monitoring of shut-down and cool-down activities

Verification that the licensee maintained defense-in-depth during outage activities

Observation and review of reduced-inventory activities These activities constituted completion of two outage samples (one refueling and one other), as defined in Inspection Procedure 71111.20.

b. Findings

No findings were identified.

1R22 Surveillance Testing

Main article: IP 71111.22

a. Inspection Scope

The inspectors observed two risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the SSCs were capable of performing their safety functions:

In-service tests:

September 15, 2016, Unit 2, service water pump A rebaseline following pump shaft, bearing, and impeller replacement Containment isolation valve surveillance tests:

August 3, 2016, Unit 1, quench tank gas sample/vent isolation valve The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.

These activities constituted completion of two surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP1 Exercise Evaluation

Main article: IP 71114.01

a. Inspection Scope

The inspectors observed the August 17, 2016, biennial emergency preparedness exercise to verify the exercise acceptably tested the major elements of the emergency plan and provided opportunities for the emergency response organization to demonstrate key skills and functions. The exercise demonstrated the licensees capability to implement its emergency plan by simulating:

A tornado touching down outside the protected area on the west side of the plant

Damage to a reactor coolant pump resulting in a manual reactor trip

Failure of the reactor to shut down on the manual reactor trip

A large break in reactor coolant system piping in containment

Failures in both trains of containment sprays

A containment penetration failure that created a filtered and monitored radiological release to the environment via the auxiliary building ventilation system During the exercise, the inspectors observed activities in the control room simulator and the following dedicated emergency response facilities:

Technical Support Center

Operations Support Center

Emergency Operations Facility The inspectors focused their evaluation of the licensees performance on the risk-significant activities of event classification, offsite notification, recognition of offsite dose consequences, and development of protective action recommendations.

The inspectors also assessed recognition of, and response to, abnormal and emergency plant conditions, the transfer of decision-making authority and emergency function responsibilities between facilities, onsite and offsite communications, protection of emergency workers, emergency repair evaluation and capability, and the overall implementation of the emergency plan to protect public health and safety and the environment. The inspectors reviewed the current revision of the facility emergency plan, emergency plan implementation procedures associated with operation of the licensees emergency response facilities, procedures for the performance of associated emergency functions, and other documents as listed in the attachment to this report.

The inspectors attended the post-exercise critiques in each emergency response facility to evaluate the initial licensee self-assessment of exercise performance. The inspectors also attended a subsequent formal presentation of critique items to plant management.

The inspectors reviewed the scenarios of previous biennial exercises and licensee drills conducted between November 2014 and July 2016, to determine whether the August 17, 2016, exercise was independent and avoided participant preconditioning, in accordance with the requirements of 10 CFR 50, Appendix E, IV.F(2)(g). The inspectors also compared observed exercise performance with corrective action program entries and After-Action reports for drills and exercises conducted between date/year and date/year to determine whether identified weaknesses had been corrected in accordance with the requirements of 10 CFR 50.47(b)(14), and 10 CFR 50, Appendix E, IV.F.

The inspectors discussed the integrated exercise with staff at the Federal Emergency Management Agency (FEMA), Region VI, to determine whether the exercise scenario supported the FEMA exercise evaluation objectives and the results continued to support that participants could adequately protect the health and safety of the public.

These activities constitute one exercise evaluation sample as defined in Inspection Procedure 71114.01.

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

Main article: IP 71114.04

a. Inspection Scope

The inspectors performed an in office review of the following documents:

Arkansas Nuclear One Emergency Plan, Revision 40

Arkansas Nuclear One Emergency Plan, Revision 41 Revision 40 made numerous changes throughout the document. Most notably, it removed the Control Room Emergency Action Level Reviewer title; replaced the Emergency Telephone Directory and call out lists with "ERO [emergency response organization] Pagers and the Emergency Telephone Directory;" replaced "Emergency Notifications Dedicated Circuit (Voice/Data)" with "Dedicated Emergency Offsite Notifications System;" replaced six-year period with eight-year period throughout document sections; and added Letter of Agreement with The National Weather Service.

Revision 41 made numerous changes throughout the document. Most notably, it clarified the roles of EOF [Emergency Operations Facility] Communicator and EOF Log Keeper, aligning titles with actual functions; deleted reference to a non-assigned position of Team Tracking Communicator, clarifying that this is a function of the work control coordinator responsibilities; defined the Technical Support Center engineering support positions as mechanical/civil and electrical/instrumentation and control; and clarified that the company spokesperson is now an assigned emergency response organization position.

These revisions were compared to their previous revisions, to the criteria of NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, and to the standards in 10 CFR 50.47(b) to determine if the revisions adequately implemented the requirements of 10 CFR 50.54(q)(3) and 50.54(q)(4). The inspectors verified that the revisions did not reduce the effectiveness of the emergency plan. These reviews were not documented in safety evaluation reports and did not constitute approval of licensee-generated changes; therefore, the revisions are subject to future inspection.

These activities constitute completion of two emergency action level and emergency plan change samples as defined in Inspection Procedure 71114.04.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

Main article: IP 71114.06

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors observed an emergency preparedness drill on July 27, 2016, to verify the adequacy and capability of the licensees assessment of drill performance. The inspectors reviewed the drill scenario, observed the drill from the simulator and emergency operations facility, and reviewed the post-drill critique. The inspectors verified that the licensees emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the licensee in the post-drill critique and entered into the corrective action program for resolution.

These activities constituted completion of one emergency preparedness drill observation sample, as defined in Inspection Procedure 71114.06.

b. Findings

No findings were identified.

1EP8 Exercise Evaluation - Scenario Review

Main article: IP 71114.08

a. Inspection Scope

The licensee submitted the preliminary exercise scenario for the August 17, 2016, biennial exercise to the NRC on June 13, 2016, in accordance with the requirements of 10 CFR 50, Appendix E, IV.F(2)(b). The inspectors performed an in-office review of the proposed scenario to determine whether it would acceptably test the major elements of the licensees emergency plan, and provide opportunities for the emergency response organization to demonstrate key skills and functions. The inspectors discussed the preliminary scenario with staff at the FEMA, Region VI, to determine whether the preliminary scenario supported the FEMA exercise evaluation objectives.

These activities constituted completion of one exercise scenario evaluation sample as defined in Inspection Procedure 71114.08.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS5 Radiation Monitoring Instrumentation

Main article: IP 71124.05

a. Inspection Scope

The inspectors evaluated the accuracy and operability of the radiation monitoring equipment used by the licensee to monitor areas, materials, and workers to ensure a radiologically safe work environment. This evaluation included equipment used to monitor radiological conditions related to normal plant operations, anticipated operational occurrences, and conditions resulting from postulated accidents. The inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance associated with radiation monitoring instrumentation, as described below:

The inspectors performed walk downs and observations of selected plant radiation monitoring equipment and instrumentation, including portable survey instruments, area radiation monitors, continuous air monitors, personnel contamination monitors, portal monitors, and small article monitors. The inspectors assessed material condition and operability, evaluated positioning of instruments relative to the radiation sources or areas they were intended to monitor, and verified performance of source checks and calibrations.

The inspectors evaluated the calibration and testing program, including laboratory instrumentation, whole body counters, post-accident monitoring instrumentation, portal monitors, personnel contamination monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air samplers, and continuous air monitors.

The inspectors assessed problem identification and resolution for radiation monitoring instrumentation. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constituted completion of the three required samples of radiation monitoring instrumentation, as defined in Inspection Procedure 71124.05.

b. Findings

No findings were identified.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

Main article: IP 71124.06

a. Inspection Scope

The inspectors evaluated whether the licensee maintained gaseous and liquid effluent processing systems and properly mitigated, monitored, and evaluated radiological discharges with respect to public exposure. The inspectors verified that abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out-of-service, were controlled in accordance with the applicable regulatory requirements and licensee procedures. The inspectors verified that the licensees quality control program ensured radioactive effluent sampling and analysis adequately quantified and evaluated discharges of radioactive materials. The inspectors verified the adequacy of public dose projections resulting from radioactive effluent discharges. The inspectors interviewed licensee personnel and reviewed licensee performance in the following areas:

During walk downs and observations of selected portions of the radioactive gaseous and liquid effluent equipment, the inspectors evaluated routine processing and discharge of effluents, including sample collection and analysis.

The inspectors observed equipment configuration and flow paths of selected gaseous and liquid discharge system components, effluent monitoring systems, filtered ventilation system material condition, and significant changes to effluent release points.

Calibration and testing program for process and effluent monitors, including National Institute of Standards and Technology (NIST) traceability of sources, primary and secondary calibration data, channel calibrations, set-point determination bases, and surveillance test results.

Sampling and analysis controls used to ensure representative sampling and appropriate compensatory sampling. Reviews included results of the inter-laboratory comparison program.

Instrumentation and equipment, including effluent flow measuring instruments, air cleaning systems, and post-accident effluent monitoring instruments.

Dose calculations for effluent releases. The inspectors reviewed a selection of radioactive liquid and gaseous waste discharge permits and abnormal gaseous or liquid tank discharges, and verified the projected doses were accurate. The inspectors also reviewed 10 CFR Part 61 analyses and methods used to determine which isotopes were included in the source term. The inspectors reviewed land use census results, offsite dose calculation manual changes, and significant changes in reported dose values from previous years.

Problem identification and resolution for radioactive gaseous and liquid effluent treatment. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constituted completion of the six required samples of radioactive gaseous and liquid effluent treatment program, as defined in Inspection Procedure 71124.06.

b. Findings

No findings were identified.

2RS7 Radiological Environmental Monitoring Program

Main article: IP 71124.07

a. Inspection Scope

The inspectors evaluated whether the licensees radiological environmental monitoring program quantified the impact of radioactive effluent releases to the environment and sufficiently validated the integrity of the radioactive gaseous and liquid effluent release program. The inspectors also verified that the licensee continued to implement the voluntary Nuclear Energy Institute (NEI)/Industry Ground Water Protection Initiative.

The inspectors reviewed or observed the following items:

The inspectors observed selected air sampling and dosimeter monitoring stations, sampler station modifications, and the collection and preparation of environmental samples. The inspectors reviewed calibration and maintenance records for selected air samplers, composite water samplers, and environmental sample radiation measurement instrumentation, and inter-laboratory comparison program results. The inspectors reviewed selected events documented in the annual environmental monitoring report and significant changes made by the licensee to the offsite dose calculation manual as the result of changes to the land census. The inspectors evaluated the operability, calibration, and maintenance of meteorological instruments and assessed the meteorological dispersion and deposition factors. The inspectors verified the licensee had implemented sampling and monitoring program sufficient to detect leakage from structures, systems, or components with credible mechanism for licensed material to reach ground water and reviewed changes to the licensees written program for identifying and controlling contaminated spills/leaks to groundwater.

Groundwater protection initiative implementation, including assessment of groundwater monitoring results, identified leakage or spill events and entries made into 10 CFR 50.75

(g) records, licensee evaluations of the extent of the contamination and the radiological source term, and reports of events associated with spills, leaks, and groundwater monitoring results.

Problem identification and resolution for the radiological environmental monitoring program. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constituted completion of the three required samples of radiological environmental monitoring program, as defined in Inspection Procedure 71124.07.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation (71124.08)

a. Inspection Scope

The inspectors evaluated the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material. The inspectors interviewed licensee personnel and reviewed the following items:

Radioactive material storage, including waste storage areas including container labeling/marking and monitoring containers for deformation or signs of waste decomposition.

Radioactive waste system, including walk-downs of the accessible portions of the radioactive waste processing systems and handling equipment. The inspectors also reviewed or observed changes made to the radioactive waste processing systems, methods for dewatering and waste stabilization, waste stream mixing methodology, and waste processing equipment that was not operational or abandoned in place.

Waste characterization and classification, including radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides, and processes for waste classification including use of scaling factors and 10 CFR Part 61 analyses.

Shipment preparation, including packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifests.

Shipping records for LSA I, II, III, SCO I, II, Type A, or Type B radioactive material or radioactive waste shipments.

Problem identification and resolution for radioactive solid waste processing and radioactive material handling, storage, and transportation. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constituted completion of the six required samples of radioactive solid waste processing, and radioactive material handling, storage, and transportation program, as defined in Inspection Procedure 71124.08.

b. Findings

No findings were identified.

The inspectors reviewed the licensees mitigating system performance index data for the period of July 1, 2015, through June 30, 2016, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the mitigating system performance index for heat removal systems for Unit 1 and 2, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

Main article: IP 71152

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Semiannual Trend Review

a. Inspection Scope

The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, and other documentation to identify trends that might indicate the existence of a more significant safety issue. The inspectors verified that the licensee was taking corrective actions to address identified adverse trends. The inspectors also reviewed the licensees progress in addressing a several licensee-identified trends.

These activities constituted completion of one semiannual trend review sample, as defined in Inspection Procedure 71152.

b. Observations and Assessments The inspectors did not identify any new adverse trends. The inspectors reviewed the adverse trends identified for all site departments and the station. The inspectors concluded that the licensee is appropriately addressing identified trends within the corrective action program.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summaries On July 1, 2016, the inspectors presented the radiation safety inspection results to Mr. T. Evans, General Manager of Plant Operations, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On July 7, 2016, the inspectors discussed the in-office review of the preliminary scenario for the August 17, 2016, biennial exercise with Mr. R. Carey, Manager, Emergency Preparedness, and other members of the licensee staff. The licensee acknowledged the issues presented.

On July 14, 2016, the inspectors debriefed Mr. C. ODell, Technical Assistant, General Manager, Plant Operations, and other members of the licensee staff of the results of the licensed operator requalification program inspection. The results of the inspection were telephonically exited with Mr. R. Martin, Operations Training Superintendent, and other members of the licensee staff on September 7, 2016. The licensee representatives acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

On September 8, 2016, the inspectors presented the results of the on-site inspection of the biennial emergency preparedness exercise conducted August 17, 2016, to Mr. T. Evans, General Manager of Plant Operations, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On October 6, 2016, the inspectors presented the resident inspectors inspection results to Mr.

R. Anderson, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

4OA7 Licensee-Identified Violations

The following violations of very low safety significance (Green) were identified by the licensee and each is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a Non-Cited Violation.

.1 Failure to Provide an Accurate Shipping Description on a Transport Manifest

Title 10 CFR 71.5, Transportation of Licensed Material, requires each licensee who transports licensed material outside the site of usage, as specified in the NRC license, or where transport is on public highways, or who delivers licensed material to a carrier for transport, to comply with the applicable requirements of the DOT regulations in 49 CFR Parts 107, 171 through 180, and 390 through 397, appropriate to the mode of transport.

Title 49 CFR 172.202(a) requires, in part, that the shipping description of a hazardous material on the shipping paper must include the identification number and the proper shipping name.

Contrary to the above, on September 11, 2014, the licensee failed to include the correct identification number and the proper shipping name on the shipping paper of a hazardous material shipment. Specifically, the shipping manifest for shipment RSR 14-099 incorrectly described the package as UN2915, Radioactive Material, Type A Package, 7, Fissile Excepted RQ - Radionuclides. The correct description was UN3321, Radioactive Material, Low Specific Activity (LSA-II), 7. This occurred due to an error with RADMAN (versions 8 and 9.1.1), a radioactive materials management software program the licensee used to characterize, classify, manifest, and document packaged radioactive waste for shipment. This issue was identified on September 17, 2015, during the licensees quality assurance audit for Radwaste and Radiation Protection, QA-14/15-2015-ANO-01.

The failure to provide the correct identification and proper shipping name on the shipping manifest is a performance deficiency. It adversely affected the Public Radiation Safety cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain. Using the Transportation branch of IMC 0609, Appendix D, the inspectors determined this violation to be of very low safety significance (Green) because:

(1) radiation limits were not exceeded;

(2) there was no breach of a package during transit;

(3) it did not involve a certificate of compliance issue;

(4) it was not a low level burial ground nonconformance; and

(5) it did not involve a failure to make notifications or provide emergency response information.

In response to this issue, the licensee conducted an evaluation and extent of condition review from 2013 to 2015, but did not find any additional shipments with this error. They conducted training and updated their version of RADMAN used to characterize their shipments. The licensee documented the issue in their corrective action program as Condition Report CR-ANO-C-2015-03683.

.2 Failure to Properly Ship Radioactive Material in Quantities of Concern with a Transportation

Security Plan Title 10 CFR 71.5, Transportation of Licensed Material, requires each licensee who transports licensed material outside the site of usage, as specified in the NRC license, or where transport is on public highways, or who delivers licensed material to a carrier for transport, to comply with the applicable requirements of the DOT regulations in 49 CFR Parts 107, 171 through 180, and 390 through 397, appropriate to the mode of transport.

Title 49 CFR 172.800(b)(15) requires, in part, that each person who offers for transportation in commerce or transports in commerce hazardous materials of International Atomic Energy Agency (IAEA) Code of Conduct Category 1 and 2 materials as defined in 49 CFR 173.403 or known radionuclides in forms listed as Radioactive Material in Quantities of Concern (RAM-QC) by the NRC, must develop and adhere to a transportation security plan for hazardous materials.

Contrary to the above, on September 11, 2014, the licensee failed to adhere to a transportation security plan for hazardous materials. Specifically, the licensee shipped a hazardous material package, shipment 14-099, which contained a Category 2/RAM-QC quantity of cobalt-60 without identifying the shipment as RAM-QC or making appropriate notifications, as required by Procedure EN-RW-106, Integrated Transportation Security Plan, the document used by the licensee to adhere to the DOT security plan requirements .

The issue was identified during an audit on October 1, 2014, while reviewing radioactive waste shipment documents. The licensee determined that the Category 2 threshold values were not appropriately listed in Revision 2 of Procedure EN-RW-106. As corrective actions, the licensee made corrections to the RAM-QC table in Procedure EN-RW-106, Revision 3, and alerted the industry of this issue.

The failure to adhere to a transportation security plan for shipping Category 2/RAM-QC hazardous materials is a performance deficiency. It adversely affected the Public Radiation Safety cornerstone objective to ensure adequate protection public health and safety from exposure to radioactive materials released into the public domain. Using the Transportation branch of IMC 0609, Appendix D, the inspectors determined this violation to be of very low safety significance (Green) because:

(1) radiation limits were not exceeded;

(2) there was no breach of a package during transit;

(3) it did not involve a certificate of compliance issue;

(4) it was not a low level burial ground nonconformance; and

(5) it did not involve a failure to make notifications or provide emergency response information.

In response to this issue, the licensee performed an extent of condition review of shipments made between January 2010 and March 2014. Six additional shipments that failed to meet the transportation security plan requirements were identified. The licensee documented this issue in their corrective action program as Condition Reports CR-ANO-C-2014-02543 and CR-ANO-C-2014-03341.

.3 Failure to Maintain Exam Integrity

Title 10 CFR 55.49, Integrity of Examination and Tests, requires, in part, that licensees or facility licensees shall not engage in any activity that compromises the integrity of any required exam. The exam is considered compromised if any activity, regardless of intent, affected, or but for detection, would have affected the equitable and consistent administration of the exam. Contrary to the above, on July 7, 2016, the licensee performed an activity that compromised the integrity of a required exam. Specifically, a licensee staff member sent licensed operator examination material to an NRC inspector via electronic mail. The files, which were the job performance measure (JPM) portion of an operating test, were password-protected. However, the file titles described what the JPM tasks were and whether the tasks were alternate path or not. While performing procedural tasks to ensure receipt of materials by the NRC, licensee staff recognized the error. After discussion of the issue with the NRC lead inspector, the affected examination material was replaced by the licensee prior to usage. The violation was of very low safety significance because, if left uncorrected, the available knowledge of the examinations content could have challenged the equitable and consistent administration of the examination, and thus required the replacement of materials on an NRC examination. This licensee entered this issue into their corrective action program as CR-ANO-2-2016-2614.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Anderson, Site Vice President

T. Arnold, Manager, Training

D. Barborek, Engineer

R. Barnes, Director, Regulatory Affair & Performance Indicators

L. Blocker, Nuclear Oversight Manager

D. Burnett, Director, Emergency Preparedness, Entergy South

P. Butler, Design and Program Engineering Manager

R. Carey, Manager, Emergency Preparedness

T. Chernivec, Outage Manager

L. Cook, Chemistry Specialist

R. Cope, Senior Chemistry Specialist

B. Daiber, Recovery Manager

B. Davis, Engineering Director

T. Evans, General Manager of Plant Operations

R. Fletcher, Supervisor, Instruments and Controls

A. Freeman, Supply Chain Manager

M. Gibson, ALARA Specialist, Radiation Protection

R. Gordon, Projects Manager

K. Hodges, Supervisor, Instruments and Controls

T. Hogrefe, Supervisor, Radiation Protection

D. James, Director, Regulatory Affairs and Recovery

T. Johnson, Supervisor, Instruments and Controls

J. Jones, Lead Technician, Instruments and Controls

B. Lynch, Manager, Radiation Protection

R. Martin, Superintendent, Operations Training

D. Marvel, Radiation Protection Manager

M. McCullah, Specialist, Radiation Protection

S. Moore, Technician, Instruments and Controls

S. Morris, Manager, Chemistry

N. Mosher, Licensing Specialist

C. ODell, Technical Assistant to the General Manager

D. Pehrson, Unit 1 Assistant Operations Manager

D. Perkins, Operations Manager

J. Prince, Senior Technician, Instruments and Controls

M. Prock, Supervisor, Chemistry

S. Pyle, Regulatory Assurance Manager

B. Sebring, Radwaste Supervisor, Radiation Protection

T. Sherrill, Assistant Manager of Operations

B. Short, Senior Licensing Specialist

G. Sullins, Regulatory and Performance Improvement Director

J. Toben, Senior Manager, Project Management Regulatory and Performance Improvement

Other Contacts

N. Williams, Chairman, Regional Assistance Committee, FEMA Region VI

Attachment 1

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

None.

LIST OF DOCUMENTS REVIEWED