ML20216C986
| ML20216C986 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 09/05/1997 |
| From: | Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Hutchinson C ENTERGY OPERATIONS, INC. |
| References | |
| 50-313-97-13, 50-368-97-13, NUDOCS 9709090185 | |
| Download: ML20216C986 (3) | |
See also: IR 05000313/1997013
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NUCLEAR REGULATORY COMMISSION
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AR LINGToN. T E XAS 760114064
September 5,1997
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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 13; 50 368/97 13 AND NOTICE OF
VIOLATION AND NOTICE OF DEVIATION
Dear Mr. Hutchinson:
Thank you for your letters of July 28 and August 25,1997, in response to our letter,
Notice of Violation, and Notice of Deviation dated June 28,1997, and telephone call on
August 21,1997. Our review of your reply found it responsive to the concerns raised in
our Notice of Deviation.
However, with respect to your initial response to the Notice of Violation, we found your
statement that full compliance was achieved on June 2,1997, was not correct.
Specifically, Arkansas Nuclear One, Unit 1, Valves CA 61, CA 62, BW 2, and BW 3 had
not been tested. As a result of our telephone call on August 21,1997, during which we
requested clarification, you responded by letter dated August 25,1997, Your response
stated that the above four valves would be tested under a work plan to meet the quarterly
testing frequency, and that test ' rocedures would be developed and implemented by
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Ceptember 30,1997. It is our understanding that all other valves identified in the Notice
of Violation have been appropriately tested and found to be acceptab e. Please inform us if
our understanding is not correct.
We will review the implementation of your corrective actions during a future inspection to
determine that full compliance has been achieved and will be maintained.
Sincerely,
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Arthur T, How 1 Ill, Director
Division of Reactor Safety
Docket Nos.: 50 313; 50 368
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Executive Vice President
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Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286 1995
~ Vice President
Operations Support
Entergy Operatior.s, Inc.
P.O. Box 31995
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Jackson, Mississippi 39286
Manager, Washington Nuclear Operations
ABB Combustion Engineering Nuclear
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David D. Snellings, Jr., Director
Division of Radiation Control and -
Emergency Management
4815 West Markham Street, Mall Slot 30
Little Rock, Arkansas 72205 3867
Manager.
Rockville Nuclear Licensing
Framatome Technologies
1700 Rockville Pike, Suite 525
. Rockville, Maryland 20852
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August 25,1997
OCAN089707
U. S. Nuclear Regulatory Commission
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Document Control Desk
Mail Station OPl 17
Washington, DC 20555
Subject:
Arkansas Nuclear One- Units 1 and 2
Docket Nos. 50-313 and 50 368
SupplementalResponse To
Inspection Report 50-313/97-13; 50-368/9713
Gentlemen:
'
On July 28,1997, Arkansas Nuclear One responded to the notice of violation identified during
the inspection of activities associated with the Inservice Testing Program (IST). The violation
pertained to the failure to include requirad ASME Code valves in the IST program and a
failure to verify the ability of other valves, tvhich were included in the IST program, to fulfill
their closed safety function.
The response stated that full compliance was achieved on June 2,1997, when the affected
valves had been successfully tested or proven operable with an operability assessm.ent.
Ilowever, following discussions with .the region and upon further review, it has been
determined that full compliance will not be achieved until the affected valves are included in
the IST program.
To demonstrate continued operability, each valve is scheduled to be tested before the end of
its quarterly test interval.
Unit I valves BW-4A, BW-4B, CA-61, CA-62, BW 2, and BW-3 will be tested under a work
plan to meet the quarterly testing frequency, If the special test developed under the work plan-
-is not satisfactorily completed, an assessment will be performed to determine continued
operability of the valves. The results of the work plan will be used to develop test procedures
by September 30,1997,'
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Test procedures for Unit 2 valves 2FP-31, 2FP-46, 2SW-56, 2SW-5'i, 2SW-62, 2SW 67,
2SW-138,- 2BS-1 A, and 2BS-1B have been developed and the quarterly tests scheduled.
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August 25,1997
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OCAN089707 Page 2
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Full compliance for the notice of violation will be achieved on September 3.,1997, when the
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test procedures for each of the valves are developed, implemented, and included in the IST
program.
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Very truly yours,
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Dwight C. Mims
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Director, Licern'ng
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- U. S. NRC
August 25,1997
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OCAN089707 Page 3
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cc:
Mr. Ellis W. Merschoff
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Regional Administrator
U. S. Nuclear Regulatory Commission
RegionIV
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611 Ryan Plaza Drive, Suite 400
Arlington, TX 76011-8064
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NRC Senior Resident Inspector
Arkansas Nuclear One
1448 S. R. 333
RusselMlle, AR72801
Mr. George Kaln.an
NRR Project Manager Region IV/ANO-1 & 2
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U. S. Nuclear Regulatory Commission
NRR Mail Stop 13-H-3
One White Flint North
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Rockville, MD 20852
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July 28,1997
OCAN079709
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U. S. Nuclear Regulatory Commission
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Document Control Desk
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Mail Station PI-137
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Subject:
Arkansas Nuclear One
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Docket Nos. 50-313 and 50-368
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Response to Inspection Report
50-313/97-13; 50-368/97-13
Gentlemen:
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Pursuant to the provisions of 10CFR2.201, attached is the response to the notice of violation
identified during the inspection activities associated with the. Inservice Testing Program and
the response to the notice of deviation identified during the inspection activities associated
with commitments to perform radiographic and ultrasonic examinations.-
Should you have questions or comments, please call me at 501-858-4601.
Very truly yours,
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Dwight C. Mims
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Director, Nuclear Safety
DCM/RMC
Attachments
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July 28,1997--
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OCAN079709 Page 2
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cc:
Mr. Ellis W. Merschoff
Regional Administrator
U. S. Nuclear Regulatory Commission
Region IV -
611 Ryan Plaza Drive, Suite 400
Arlington, TX 76011-8064
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NRC Senior Resident Inspector
Arkansas Nuclear One
P.O. Box 310
London, AR 72847
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Mr. George Kalman
NRR Project Manager Region IV/ANO-1 J. 2
U. S. Nuclear Regulatory Commission -
NRR Mail Stop 13-H-3
One White Flint North
11555 Rockville Pike
Rockville, MD 20852
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Attachment to
OCAN079709
Page 1 of 6
NOTICE OF VIDLATION
During an NRC inspection conducted on May 12 through June 5,1997, one violation of
NRC requirements was identified. In accordance with the " General Statement of Policy
and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed
below:
10 CFR 50.55a(f) requires inservice tests to verify the operational readiness of
pumps and valves, whose function is required for safety, to comply with the
requirements set forth in Section XI of the appropriate edition and addenda of the
AShE Boiler and Pressure Vessel Code.
Article RVV-1100 of the AShE Code provides the rules and requirements for
. inservice testing to assess operational readiness of certain AShE Code Class 1,2,
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and 3, valves which are required to perform a specific function in shutting down a
reactor to the cold shutdown condition or in mitigating the consequences of an
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accident.
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Article RVV-3000 in Section XI of the AShE Code specifies the type of tests to
be performed on each category of valve, and Subarticle IWV-3412(a) states that
valves are to be exercised to the position required to fulfill their function (i.e., open
or closed).
Contrary to the above, the following conditions were identified:
1.
Seven Unit 2 AShE Code valves, which had a safety function to open and
were required to be tested in accordance with Section XI of the AShE
Code, were not included in the inservice test program. The normally closed
Category B valves were located irt the service water piping which provides
makeup water to the spent fuel,ind were identified as: 2FP-31; 2FP-46;
2SW-56; 2SW-57; 2SW-62; 2SW-67; and 2SW-138.
2.
Eight AShE Code valves (six in Unit I and two in Unit 2) that were in the
inservice test program, were not being tested or exercised to verify their
ability to fulfill their closed safety function. The Unit I valves were
identified as: BW-4A/4B (Borated Water Storage Tank Outlet Check
Valves); CA-61/62 (Sodium Hydroxide Storage Tank Outlet Check
Valves); and BW-2/3 (High Pressure Injection
Pump
Suction
Check
Valves). The Unit 2 valves were identified as: 2BS-1A/lB (Refueling
Water Tank Outlet Check Valves).
This is a Severity Level IV violation (Supp'ement 1)(50-313;-368/9713-01).
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Attachment to
OCAN079709
Page 3 of 6
Response to Notice of Violation 50-313: 368/9713 01
(1)
Reason for the violation:
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On May 19,1997, the inspector noted that the Unit 1 Borated Water Storage Tank
(BWST) Outlet Check Valves BW-4A and BW-4B were included in the inservice
test (IST) program; however, they were identified as having an open safety
function only. These valves are the first isolation valves, of dual isolation valves,
in paths from the emergency core cooling system (ECCS). Since these valves
were not identified as having a closed safety function, they were not being tested in
the closed position. ANO 2 check valves 2BS-1 A and 2BS-1B, ANO-2 Refueling
Water Tank (RWT) Outlet Check Valves were similarly identified.
. In response, a condition report was initiated. The condition report noted that prior
to 1993, IST testing of BW-4A and BW-4B consisted of valve disassembly and
manually moving the valve disk to the open and closed position per approvec' elief
requests. Additionally, four other ANO-1 valves were identified as not having a
closed safety function, yet were considered to be part of a dual isolation
configuration (CA-61, CA-62 - Sodium Hydroxide Tank Outlet Check Valves and
BW-2, BW-3 - High Pressure Injection Pump Suction Check Valves). Another
condition report action was initiated to determine if a similar condition existed on
ANO-2. As a result of further review, seven additional ANO-2 ASME Code,
safety-related, normally closed valves that have an open safety function, but were
not in the IST program, were identified. The identified valves were 2FP-31, 2FP-
46,2SW-138,2SW-56,2SW-57,2SW-62, and 2SW-67, all Category B valves in
the service water piping which provide makeup water to the spent fuel pool.
These valves, except those providing service water make-up tc. the spent fuel pool,
were previously identified for inclusion in the IST program. In the fall of 1996, an
independent review of the ANO-1 and ANO-2 IST basis documents was
performed. One of the observations made during the review was that ANO-1
valves, BW-2, BW-3, BW-4A, BW-4B, CA-61, and CA-62, had a closed safety
function. A procedure improvement form was provided to ANO-1 Operations to
inform them that the subject valves had a closed function and test procedures
needed to be developed.
Additionally, another observation from the review
identified ANO-2 valves, 2BS-1A and 2BS-1B as having a closed function and
discussions with ANO-2 Operations were ongoing.
The root cause of 2BS-1 A, 2BS-1B, BW-2, BW-3, BW-4A, BW-4B, CA-61, and
CA-62 not being reverse flow tested in the IST program was the failure to
recognize the closed safety function that these valves perform, i.e., the second of
two valves need to complete a closed system. The root cause of the seven ANO-2
service water valves not being within the IST program was not recognizing that
these valves had a safety function that fell within the scope of the IST program.
However, flow verification and preventive maintenance activities are performed on
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Attachment to
OCAN079709
Page 4 of 6
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the seven ANO-2 service water valves which has been considered to more
adequately assess the valve's condition than manually stroking the valve quarterly.
(2)
Corrective actions taken and results achieved:
Check valves BW-4A, BW-4B,2BS-1A, and 2BS-1B were successfully tested to
demonstrate their ability to close.
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An operability assessment for valves CA-61, CA-62, BW-2, and BW-3 was
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performed and the valves were determined to be operable based on recent
surveillance test information and periodic maintenance.
The ANO-2 service water valves, 2FP-31, 2FP-46, 2SW-138, 2SW-56, 2SW-57,
,2SW-62, and 2SW-67, were tested successfully prior to heat-up from ANO-2
refueling outage 2R12.
(3)
Corrective stens that will be taken to prevent recurrence:
Test procedures will be developed by September 30,1997, to test the identified
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ANO-l&2 valves in accordance with the IST program.
A review of engineering standards HES-17, ANO-1 IST Program Bases
Document, and HES-18, ANO-2 ISTProgram Bases Document, will be pezformed
by December 1,1997.
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An assessment of the IST program for both units will be completed by December
1,1997.
The IST program will be evaluated to determine the need for additional reviews by
other departments of changes to the IST program. This action is scheduled to be
completed by December 31,1997.
(4)
Date when full compliance will be achieved:
Full compliance was achieved on June 2,1997, when the affected valves had been
successfully tested or proven operable with an operability assessment.
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Att:chment to
OCAN079709
Page 2 of 6
NOTICE OF DEVIATION
During an NRC inspection conducted on May 12 through June 5,1997, one deviation
from a commitment was identified. In accordance with the " General Statement of Policy
and Procedure for NRC Enforcement Action," NUREG-1600, the deviation is listed
below:
Arkansas Power & Light Co., letter ICAN048501, "HPI/ Makeup Nozzle
Component Cracking," dated April 22, 1985, submitted a fmal report titled,
"B&W Owners Group Safe-End Task Force." The letter stated that
Recommendation 3 in the report had been incorporated into the Arkansas Nuclear
One Unit 1 inservice inspection plan.
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Recommendation 3 addressed the following nozzle conditions and the associated
nondestructive examination schedule:
Unrepaired nozzles were to be examined by radiography and ultrasonics during
each of the next five refueling outages, then every finh refueling outage
thereaner,
Nozzler with the new sleeve design were to be similarly examined during the first,
third, and finh refueling outages, then every fifth refueling outage thereaner.
Nozzles that were re-rolled were to be examined by radiography during each of
the next five refueling outages, then every finh refueling outage thereafter.
Contrary to the above,12 of the 14 committed radiographic and ultrasonic
examinations scheduled for the 4 nozzles between Refueling Outage 5 and
Refueling Outage 9 were not performed.
This is a Deviation (50-313/9713-02).
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Attachment to
0CAN079709
Page 5 of 6
Response to Notice of Deviation 50-313/9713 02
(1)
Reason for the deviation:
In response to a concern that cracking could occur in the ANO-1 high pressure
injection / makeup nozzles (HPI/MU), Arkansas Nuclear One (ANO) committed to
perform augmented radiographic and ultrasonic examinations on these nozzles per
Babcock and Wilcox (B&W) recommendations in 1985.
The augmented
examinations were included in the Inservice Inspection Program (ISI) and were
scheduled for performance during five consecutive refueling outages (IRS through
IR9) and then during each finh refueling outage thereafter (IRl4, IR19, etc.).
The radiographic testing was to ensure no gap existed between the thermal sleeve
and the safe end and to detect nozzle degradation. The ultrasonic testing was to
. detect cracking of the safe end and the adjacent pipe.
The augmented examinations were performed during IR5 (November 1982 - May
1983) and IR6 (October 1984 - January 1985) and only partially completed during
IR7 (Septembei 1986 - December 1986) due to program scheduling errors. The
augmented radiographic examinations scheduled for 1R8 (October 1988 -
December 1988) were cancelled due to ALARA concerns without first evaluating
the NRC commitment to perform the examinations.
In September 1989, ANO self-identified the failure to perform the augmented
examinations during IR7 and IR8 as previously committed to the Nuclear
Regulatory Commission (NRC). An evaluation was performed to determine if the
augmented examinations should be performed during a mid-cycle outage or to
delay inspections until IR9 scheduled for October 1990.
The evaluation
concluded that since the previous augmented examination results were satisfactory
and since the nozzle thermal shields were visually inspected during 1R8 and found
to be intact, the augmented examinations could be delayed until IR9 (October
1990 - January 1991). The examinations performed during 1R9 were deemed
satisfactory.
In response to the April 21,1997, HPI nozzle leak at Oconee 1, ANO reviewed
radiographs and ultrasonic examinations performed during IR9 on the ANO-1
HPI/MU nozzles and determined that the anomaly (gap between the thermal sleeve
and safe end) that caused the Oconee leak was not present in the ANO-1 nozzles.
The examiners of the HPI/MU nozzle radiographs taken during past refueling
outages did not document whether or not gaps existed between the thermal sleeve
and the safe end area, even though the radiographs specifically depicted the
thermal sleeve / safe end area.
Based on the 1997 evaluation of the past HPI/MU nozzle radiographs and
ultrasonic examination test results ANO determined that additional augmented
examinations were unnecessary and that the examinations could be performed on
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Attachm:nt to
0CAN079709
Page 6 of 6
the five refueling outage frequency as previously committed. The augmented
examinations for the HPI/MU nozzles are currently scheduled to be performed
during IR14 (Spring 1998) and every fifth refueling outage thereafter.
Since 1989 when this deviation occurred, the ANO procedure revision process and
the ANO commitment management program has undergone several enhancements.
The current ANO procedure revision process requires that pending procedure
changes that alter or delete existing regulatory commitments be resolved per the
ANO commitment management program prior to implementing the change. The
ANO commitment management program is currently based on the Nuclear Energy
Institute's GuidelinesforManaging NRC Commitments. Commitment changes or
deletions are periodically reported to the NRC based on these guidelines.
(2) . Corrective actions taken and results achieved:
The ANO 1 ISI Program was revised to include specific criteria for examination of
the thermal sleeve to safe end area for gaps on the HPI/MU nozzles.
The ANO-1 ISI Program was reviewed to ensure that the required augmented
examinations had been scheduled on the five refueling outage frequency.
(3)
Actions taken to avoid further deviations:
Actions completed to date should avoid further deviations in this area.
(4)
Date when corrective actions will be completed:
Corrective actions were completed on May 2,1997, when the evaluation of the
HPI/MU nozzle radiographs taken during IR9 determined that there were no gaps
in the thermal sleeve to safe end areas.
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