IR 05000313/1993031

Discusses Insp Repts 50-313/93-31 & 50-368/93-31 on 931021-25 & Forwards Notice of Violation

ML20058M043
Person / Time
Site:	Arkansas Nuclear
Issue date:	12/14/1993
From:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Yelverton J ENTERGY OPERATIONS, INC.
Shared Package
ML20058M046	List: IR 05000313/1993031 ML20058M049
References
EA-93-278, NUDOCS 9312200124
Download: ML20058M043 (5)

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. g4;Er UNITED STATES ug'C g f NUCLEAR REGULATORY COMMISSION'

j R EGION IV j

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o 'E 611 RYAN PLAZA DRIVE, SulTE 400 -

ARLINGTON, TEXAS 760114064 f

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DEC l 41993 Docket Nos. 50-313; 50-368 ,

License Nos. DPR-51; NPF-6 .

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EA 93-278 Entergy Operations, In ATTN: J. W. Yelverton Vice President Operations Arkansas Nuclear One ,

Route 3, Box 137G '

Russellville, Arkansas 72801 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-313/93-31; 50-368/93-31)

This is in reference to the inspection conducted October 21-25, 1993, at the Arkansas Nuclear One (ANO) nuclear power plant, Units 1 and 2. This inspection was conducted to review the circumstances surrounding Entergy-l Operations, Inc.'s discovery on October 1,1993, that the ANO Unit I reactor building sump did not meet design criteria. Plant personnel found unscreened openings into the sump and tears in the existing screening material that >

covered the sump. On October 22; 1993, plant personnel found unscreened l openings associated with the ANO Unit 2 reactor building sump. .Entergy l Operations submitted Licensee Event Reports on November 12 and-22, 1993, describing the results of its findings with respect to ANO Units 1 and 2, respectively. A report documenting the results of our inspection was issued on November 16, 1993. On November 23, 1993, you.and other Entergy Operations, Inc. representatives attended an enforcement conference in the NRC's Arlington, Texas office to discuss NRC's preliminary conclusion that -

potentially significant violations of NRC requirements had occurre l l

Based on the NRC's review of information developed during the inspection and- !

the information exchanged during the enforcement conference, the NRC'has  ;

concluded that Entergy Operations violated 10 CFR _Part 50, Appendix B,  !

Criterion III, " Design Control," by failing to assure that the reacto i building sump screens in both units were designed, installed and maintained in !

accordance with design specifications described in the Final Safety Analysis l

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Reports. Criterion III states, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are  !

correctly translated into specifications, drawings, procedures and l instructions.

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As described in more detail in the inspection report and the LERs submitted by .

Entergy Operations, plant personnel found numerous unscreened openings into I the sumps and openings in existing screens that would have permitted debris to

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bypass the screens and enter the reactor building sumps. Many_of these '

openings had existed since'initi:ll plant construction due to an apparent l failure to assure that design basis requirements were followed during  ;

construction. The violations described in the enclosed Notice of. Violation !

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p93 2200124 931214 G ADOCK 05000313 PDR ,

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Entergy Operations, la are considered significant because the sumps provide a long-term source of cooling water for various Emergency Core Cooling and safety systems following an accident and the screens are designed to prevent debris from interfering with the operation of these systems. During the enforcement conference, Entergy Operations described the results of its evaluations and concluded that, at worst, the screen integrity problems could have degraded the operation of safety systems following various Loss of Coolant Accidents (LOCAs) but would not have resulted in a loss of system function. Based on this conclusion and the results of the NRC's independent analysis, which does not disagree substantially with that performed by Entergy Operations, the violations involving ANO Unit 1 and 2 have been classified in the aggregate as a Severity Level III problem in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy) 10 CFR Part 2, Appendix C, Supplement I, 0.2.(b).

While the NRC commends Entergy Operations personnel for identifying and correcting these problems at this time, we also conclude that Entergy Operations had several opportunities to identify and correct this condition earlier. In addition to the many opportunities during physical inspections of the reactor building sumps at the conclusion of each refueling outage, the NRC provided specific notice of potential sump screen problems in Information Notice 89-77, " Debris in Containment Emergency Sumps and Incorrect Screen Configurations." Although this notice alerted all licensees to the potential for gaps in screens, missing screens and damaged screens, as well as the potential for debris in sumps, Entergy Operations' response to this notice focused only on the need to assure that the sumps _were free of debris and failed to focus on the need to assure the integrity and proper configuration of the screen NRC recognizes that Entergy Operations took prompt corrective action to repair and restore the reactor building sump screens to their design basis and has taken or developed actions to address potential weaknesses revealed by this discovery. Other actions include an assessment of other components vulnerable to the same errors in design and construction, a review of discrepancies discovered during the ongoing design basis reconstitution process to assure no immediate safety concerns, a review of the plant's current design control processes, and a review of the processes for responding to NRC information notice In accordance with the Enforcement Policy, a civil penalty is considered for a Severity Level III problem. However, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research, not to propose a civil penalty in this case based on the application j of the civil penalty adjustment factors discussed in Section VI.B.2 of the Enforcement Policy. This determination was based on the following considerations: 1) The problems related to the sump screens were identified by Entergy Operations personnel (minus 50%); 2) Entergy Operations' corrective actions following tne identification of these problems were prompt and l

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Y Entergy Operations, In comprehensive (minus 50%); 3) Entergy Operations' performance in safety assessment / quality verification and overall performance in identifying and correcting historical problems has been good (minus 100%); and 4) Entergy Operations had several earlier opportunities to have identified the specific problems in this case (plus 100%). The remaining civil penalty adjustment factors were considered but no further adjustments were deemed appropriat Entergy Operations, Inc. is required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing its response. In its response, Entergy Operations, Inc. should document the specific actions taken and any additional actions it plans to prevent recurrence. After reviewing Entergy Operations' response to this Notice, including its proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirement In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Roo The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No. 96-51

Sincerely, wL. 777L ames L. Milhoan egional Administrator Enclosure: Notice of Violation cc w/ Enclosure:

Entergy Operations, In ATTN: Harry W. Keiser, Executive Vice President & Chief Operating Officer P.O. Box 31995 Jackson, Mississippi 39286-1995 Entergy Operations, In ATTN: John R. McGaha, % ::.e President Operations Support P.O. Box 31995 Jackson, Mississippi 39286  ;

Wise, Carter, Child & Caraway ATTN: Robert B. McGehee, Es P.O. Box 651 Jackson, Mississippi 39205

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Entergy Operations, In ,

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Honorable C. Doug Luningham County Judge of Pope County i Pope County Courthouse  ;

Russellville, Arkansas .72801  ;

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Winston &'Strawn .

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ATTN: Nicholas S. Reynolds, Es L Street, Washington, Arkansas Department of Health  !

ATTN: Ms. Greta Dicus, Director  : l Division of Radiation Control and  ?

Emergency Management l 4815 West Markham Street l Little Rock, Arkansas 72201-3867 >

i B&W Nuclear Technologies <

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ATTN: Robert B. Borsum  ;

Licensing Representative I 1700 Rockville Pike, Suite 525  !

Rockville, Maryland 20852 Admiral Kinnaird R. McKee, USN'(Ret)~ I 214 South Morris Street Oxford, Maryland 21654  ;

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ABB Combustion Engineering

, ATTN: Charles B.- Brinkman Manager, Washington '

Nuclear Operations 12300 Twinbrook Parkway, Suite 330  ;

Rockville, Maryland 20852 '

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1f Entergy Operations, In H0 DISTRIBUTION:

PDR LPDR SECY CA JTaylor, ED0 JSniezek, DEDR TMurley, NRR LJCallan, NRR/ADP JLieberman, OE (4)(I-single sided)

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RIV DISTRIBUTION:

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