ML20199C486
| ML20199C486 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/18/1997 |
| From: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Hutchinson C ENTERGY OPERATIONS, INC. |
| Shared Package | |
| ML20199C490 | List: |
| References | |
| 50-313-97-14, 50-368-97-14, EA-97-382, NUDOCS 9711200032 | |
| Download: ML20199C486 (5) | |
See also: IR 05000313/1997014
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November 18, 1997
EA 97-382
C. Randy Hutchinson, Vice President
Operations
Arkansas Nuclear One
Entergy Operations, Inc.
1448 S.R. 333
Russellville, Arkansas 72801-0967
SUBJECT:
(NRC INSPECTION REPORT 50-313/97-14; 50-368/97-14)
Dear Mr. Hutchinson:
This is in reference to the predecisional enforcement conference held in the NRC's Arlington,
Texas office on September 26,1997. The conference was conducted to discuss three
apparent violations of NRC requirements related to inspections of steam generator tubes at
Arkansas Nuclear One, Units 1 and 2. The results of our inspection were discussed with
your staff during a telephonic exit briefing conducted on August 8,1997, and were
documented in the subject NRC Inspection Report, which was issued September 12,1997.
After the September 26 conference, ANO provided further information and clarification during
a telephone discussion held on October 2,1997.
The three apparent violations described in the inspection report involved: (1) a failure to
comply with 10 CFR Part 50 Appendix B Criterion IX in the use of data in bobbin coil sizing
qualification criteria that did not conform to the requirements of the selected qualification
method; (2) the failure to remove Unit 2 tubes from service which contained flaws that
exceeded the plugging limit of the Technical Specifications; and (3) the lac!; of prompt
corrective action in November 1995 prior to-retuming potentially defective sleeved tubes to
service.
During the September 26 conference, Enter' y expressed disagreement with the first apparent
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violation, contending that Entergy's sizing qualification for intergranular attack (IGA) met the
provisions of appropriate industry qualification processes (EPRI Appendix "H"), and therefore
Entergy was in compliance with 10 CFR Part 50 Appendix B. With regard to the second
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apparent violation, which involved Unit 2 steam generators, Entergy agreed that the violation
occurred but contended that the violation warranted treatment as a non-cited violation.
Entergy also disputed the third apparent violation, which is discussed below.
The NRC considered Entergy's arguments and has concluded that vic;dions of NRC
requirements occurred. The violations are cited in the enclosed Notice of Violation (No
Based on the discussions at the conference, we have modified the first violation to state that
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Entergy's inservice inspections of Unit 1 steam generators were not appropriately controlled
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, and accumplished to identify tube defects that exceeded the technical specification plugging
9711200032 971118
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Entergy Operations, Inc.
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limit. The second violation involves Unit 2 steam generator tubes, with defects greater than
' the technical specification plugging limit, that were improperly considered operable.
Although these violations involve steam generators of different designs and different IGA flaw
sizing methodologies, the violations are similar in that your methods for sizing lGA and tubing
degradation in both Units 1 and 2 steam generators were shown to have been inadequate.
The actual safety consequence of these violations is low because no significant leakage
occurred as a re: ult of tube leaks. These issues are of regulatory significance because of
the programmatic nature of the problem; that is, you relied on methods which were incapable
of detecting flaws greater than the plugging limit, and as a result, operated Units 1 and 2 with
steam generators with tubes containing flaws that exceeded the technical specification
plugging limit of 40 percent through wall (TW). Therefore, these two violations have been
categorized in the aggregate in accordance with the " General Statement of Policy and
Procedure for WRC Enforcement Actions"(Enforcement Policy), NUREG-1600, as a Severity
Level lli problem.
In accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000 is
considered for a Severity Level 111 problem. Because your facility has been the subject of
escalated enforcement actions within the last 2 years', the NRC considered whether credit
was warranted for Identification and Corrective Action in accordance with the civil penalty
assessment process in Section VI.B.2 of the Enforcement Policy. Since Entergy identified
both issues, the NRC has determined that Entergy is deserving of identification credit.
Further, the NRC has determined that Entergy is deserving of Corrective Action credit.
Entergy's corrective actions for the first violation included declaring the steam generators
inoperable, notifying the NRC, requesting (and being granted) a Notice of Enforcement
Discretion from the NRC, administratively precluding IGA sizing, and investigating the cause
of the problem. Entergy's corrective actions to the second violation included reviewing more
"no detectable degradation" determinations to verify the quality of the 2R12 analyses,
performing enhanced inservice inspectio".s of indications, repairing the eggerate cracks,
enhancing training, and providing additional oversight of the inservice inspections.
Therefore, to encourage prompt identification and comprehensive correction of violations, I
have been authorized not to propcse a civil penalty in this case. However, significant
violations in the future could result in a civi! penalty.
The third violation cited in the enclosed notice involves Entergy's failure to take prompt
corrective actions prior to retuming to service potentially defective sleeved tubes exhibiting
weld zone eddy current indications. At the conference, Entergy representatives expressed
disagreement with this violation, contending that sufficient technical basis existed (including
' A Severity Level 111 problem and a $50,000 civil penalty was issued on April 9,1997,
involving fire protection inadequacies and the plant staff's inadequate response to
ind:ations of a fire (EA 96-512).
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Entergy Operations, Inc.
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ultrasonic testing and visual testing) to justify use of the sleeves as-is. Further, Entergy
representatives noted thet, after re-inspection, only one of 28 indications was identified for
repair based on new acceptance criteria and that all 28 indications met structural and
leakage requirements; Notwithstanding Entergy's argument that the structural integrity of the
sleeves was maintained, the NRC's position is that Entergy had an indication of a condition
adverse _to quality, and it took inadequate corrective actions. Specifically, your actions (in
October 1995, during 2R11) were not adequate to evaluate defects that existed at the time,
nor did you perform an operabrity assessment at the time. Therefore, in accordance with the
its Enforcement Policy, the NRC has classified this violation et Severity Leve,l IV.-
You are required to respond to this letter and should follow the instructions specified in the -
encksed 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 deteimine whether further enforcement action is necessary
to ensure compliance with regulatory requirements,
in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its
enclosure, arid your response will be placed in the NRC Public Document Room (POR).
Sincerely,
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Ellic W. Mers
Regional Adm'iistrator
Dockets:
50-313-
50-368
Licenses: DPR 51
cc w/ Enclosure:
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Executive Vice President
& Chief Operating Officer
Entergy Operations, Inc.
,
P.O. Box 31995
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L Jackson, Mississippi 39286-1995
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Entergy Operations, Inc.
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Vice President
Operations Support
Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippl 39286-
Manager, Washington Nuclear Operations
ABB Combustion Engineering Nuclear
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Power
12300 Twinbrook Parkway, Suite 330
<
Rockville, Maryland 20852
County Judge of Pope County
Pope County Courthouse
Russellville, Arkansas : 72801
Winston & Strawn -
1400 L Street, N.W.
WasNngton, D.C. 20005 3502
David D. Snellings, Jr., Director
Division of Radiation Control and
Emergency Management
4815 West Markham Street, Mail Slot 30
Little Rock, Arkansas 72205-3867
Manager
Rockville Nuclear Licensing
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Framatome Technologies
1700 Rockville Pike, Suite 525
Rockville, Maryland 20852
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