ML20216C986

Ack Receipt of 970728 & 0825 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-313/97-13 & 50-368/97-13 on 970628

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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UNIT E D ST AT ES

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,[* 611 RYAN PLAZA drive.SuliE 400

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 ' procedures would be developed and implemented by

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

License Nos.: DPR 51; NPF-6

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Executive Vice President

& Chief Operating Officer

Entergy Operations, Inc.

P.O. Box 31995

Jackson, Mississippi 39286 1995

~ Vice President

Operations Support

Entergy Operatior.s, Inc.

P.O. Box 31995 i

Jackson, Mississippi 39286

Manager, Washington Nuclear Operations

ABB Combustion Engineering Nuclear

Power

12300 Twinbrook ?arkway, Suite 330 - 1

Rockville, Maryland 20852 ~

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County Judge of Pope County '

Pope County Courthouse

Russellville, Arkansas 72801

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Winston & Strawn

1400 L Street, N.W.

Washington, D.C. 20005 3502

David D. Snellings, Jr., Director

Division of Radiation Control and -

Emergency Management

Arkansas Department of Health

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 -

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

License Nos. DPR-51 and NPF-6

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,'

,

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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U. S. NRC

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August 25,1997 .

OCAN089707 Page 2

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g 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 .

OCAN089707 Page 3

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

U. S. Nuclear Regulatory Commission

NRR Mail Stop 13-H-3

One White Flint North

! 11555 Rockville Pike

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Rockville, MD 20852

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10CFR2.201

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July 28,1997

OCAN079709

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U. S. Nuclear Regulatory Commission ' '

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Subject: Arkansas Nuclear One k':kgl{;

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Docket Nos. 50-313 and 50-368 %v

License Nos. DPR-51 and NPF-6

Response to Inspection Report

50-313/97-13; 50-368/97-13

Gentlemen: '

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,

k'*fC*ir?fi

Dwight C. Mims

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Director, Nuclear Safety

DCM/RMC

Attachments

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U. S. NRC

, July 28,1997--

OCAN079709 Page 2 '

cc: Mr. Ellis W. Merschoff

Regional Administrator

U. S. Nuclear Regulatory Commission

Region IV -

611 Ryan Plaza Drive, Suite 400

.

Arlington, TX 76011-8064

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

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. inservice testing to assess operational readiness of certain AShE Code Class 1,2,

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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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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OCAN079709

Page 3 of 6

Response to Notice of Violation 50-313: 368/9713 01

, (1) Reason for the violation:

(

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 -

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

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:

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Test procedures will be developed by September 30,1997, to test the identified

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. '

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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