ML20137Q645
| ML20137Q645 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 04/09/1997 |
| From: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Hutchinson C ENTERGY OPERATIONS, INC. |
| Shared Package | |
| ML20137Q648 | List: |
| References | |
| EA-96-512, NUDOCS 9704110063 | |
| Download: ML20137Q645 (6) | |
See also: IR 05000313/1996027
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ARLINGTON. TEXAS 760118064
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April 9, 1997
EA 96 512
C. Randy Hutchinson, Vice President
Operations
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Arkansas Nuclear One
Entergy Operations, Inc.
1448 S.R 333
Russellville, Arkansas 72801-0967
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF civil PENALTY -
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$50,000 (NRC Inspection Report 50-313:368/96-27)
Dear Mr. Hutchinson:
This refers to the predecisional enforcement conference conducted in Arlington, Texas, on
March 28,1997 with Entergy Operations, Inc. (Entergy) representatives. The conference
was conducted to discuss apparent violations of NRC requirements associated with an
October 17,1996 fire at / rkansas Nuclear One (ANO), Unit 1, as documented in NRC -
Inspection Report 50-313:368/96-27, issued February 3,1997. The inspection was
conducted October 22-29 and November 21-25,1996, and was finalized in a telephonic
exit meeting on December 11,1996.
The apparent violations described in the inspection report involved severalinadequacies in
NRC-required reactor coolant pump oil collection systems at ANO, and three examples of
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inadequate responses to plant conditions which indicated the potential for a fire (i.e.,
inadequate corrective action, as required by 10 CFR Part 50, Appendix B, Criterion XVI).
At the conference, Entergy expressed disagreement with parts of the apparent fire
protection violations, contending that the oil collection system for the reactor coolant
pumps was not required to collect oil spray from lift oil piping leaks, nor to collect leakage
from " remote" oil filllines. Entergy did not explicitly disagree with the corrective action
violations. However, Entergy's position was that plant personnel had responded
reasonably to oilleaks and smoke in light of their lack of understanding of the " wicking"
phenomenon which created the potential for oil-soaked insulation to ignite at a lower than
expected temperature.
The NRC considered Entergy's fire protection arguments but has concluded that 10 CFR
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Part 50, Appendix R,is clear with regard to these reactor coolant pump components being
protected by oil collection systems. Based on our discussions during the conference, we
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have clarified the violation to include the failure to protect the fill connection on the Unit 1
8 reactor coolant pump and to clarify that the flanged connections were not protected on
the lower reservoir transmitters. We also deleted one of the apparent examples of an
Appendix B, Criterion XVI violation. Specifically, we deleted the examole involving oil
found on the floor of the Unit 1 containment building by radiation protection personnel
during the outage because, as discussed during the conference, the small amounts of oil
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Entergy Operations, Inc.
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involved did not represent a clear opportunity to determine the source of the leak and take
- corrective action.
Therefore, based on the information developed during the inspection and the information
that was provided during the conference, the NRC has determined that violations of NRC
requirements occurred. These violations are cited in the enclosed Notice of Violation and
.
Proposed imposition of Civil Penalty; the circumstances surrounding the violations were
described in detail in the subject inspection report.
The violations include: 1) a failure to maintain an adequate lube oil collection system for
reactor coolant pumps, which created the potential for a fire when oil spray from a cracked
weld accumulated in fibrous insulation; and 2) a failure in two instances to take prompt
action to identify and correct conditions which resulted in a fire in the ANO Unit 1
containment building on October 17,1996. These violations appt.ar to have resulted from
a lack of sensitivity to fire protection requirements related to reactor coolant pump lube oil
collection systems and to plant conditions which indicateri a potential for a containment
fire to occur.
The October 17,1996 fire was quickly extinguished and did not affect the safety of the
plant. Nonetheless, the NRC finds the fire protection inadequacies, coupled with the plant
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staff's inadequate response to indications of a fire, i.e., oil soaked insulation which was
reported to be smoking excessively during plant heat-up, unacceptable performance.
Therefore, these violations have been classified in the aggregate as a Severity Levelill
problem, in accordance with the " General Statement of Pc"cy and Procedure for NRC
Enforcement Actions" (Enforcement Policy), NUREG-1600.
The NRC acknowledges that Entergy has taken or planned a number of corrective actions
in response to these violations, all of which were discussed at the conference. In brief,
these actions involve: 1) training and procedural revisions to heighten sensitivity to smoke,
oil leaks, lube oil collection system requirements and the potential for reduced auto-ignition
temperatures of oil-soaked insulation; and 2) plant modifications and administrative
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measures to address the various inadequacies in reactor coolant pump lube oil collection
systems.
In accordance with the Enforcement Policy, a civil penalty with a base value of $50,000 is
considered for a Severity Levellli problem. Because your facility has been the subject of
escalated enforcement actions within the last 2 years,' the NRC considered whether
Entergy should be given credit for identi// cation and Corrective Action in accordance with
the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. The
violations were discovered only because the fire occurred. In that plant staff missed
opportunities to take action to prevent the fire, the NRC has determined that Entergy
should not be given credit for identification. The NRC has determined that Entergy should
' A $50,000 civil penalty was issued September 6,1996, for violations related to
improper maintenance on main steam safety valves.
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Entergy Operations, Inc.
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be given credit for its corrective actions, summarized above, which were prompt and-
comprehensive. Consideration of these factors results in the assessment of a base civil-
penalty.
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Therefore, to emphasize the importance of adherence to fire protection requirements in the
design and operation of the f acility, and the importance of reacting to plant conditions
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indicating a potential for a fire, I have been authorized, after consultation with the Director,
Office of Enforcement, to issue the enclosed Notice of Violation and Proposed imposition
of Civil Penalty (Notice) in the amount of $50,000.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. In your response, you should document
the specific ' actions taken and any additional actions you plan to prevent recurrence. The
NRC will use your response, in part, to determine whether further enforcement action is
necessary to ensure compliance with regulatory requirements.
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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,
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its enclosure, and your response will be placed in the NRC Public Document Room (PDR).
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Sincerely,,
,
,
Ellis W. Merschof
Regional Admi
ator
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Docket Nos. 50-313;50 368
License Nos. DPR-51; NPF-G
Enclosure: Notice of Violation and
Proposed imposition of Civil Penalty
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Executive Vice President
& Chief.Operatir.g Officer
Entergy Operations, Inc.
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P.O. Box 31995
Jackson, Mississippi 39286-1995
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Vice President
Operations Support
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Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286
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Entergy Operations, Inc.
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' Manager, Washington Nuclear Operations
ABB Combustion Engineering Nuclear
Power
12300 Twinbrook Parkway, Suite 330.
Rockville, Maryland 20852
County Judge of Pope County
Pope County Courthouse
Russellville, Arkansas 72801
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Winston & Strawn
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1400 L Street, N.W.
. Washington, D.C. 20005 3502
Bernard Bevill, Acting Director
- Division of Radiation Control and
Emergency Management
4815 West Markham Street, Slot 30
Little Rock, Arkansas 72205 3667
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Manager
Rockville Nuclear Licensing
Framatome Technologies
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1700 Rockville Pike, Suite 525
Rockville, Maryland 20852
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