ML20248L629

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Discusses Insp Repts 50-313/97-21 & 50-368/97-21 on 971027- 31 & 1110-14 & Forwards Notice of Violation Re Failure to Initiate Proper Design Control Measures IAW 10CFR50,App B
ML20248L629
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 03/18/1998
From: Merschoff E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Hutchinson C
ENTERGY OPERATIONS, INC.
Shared Package
ML20248L631 List:
References
50-313-97-21, 50-368-97-21, EA-97-574, NUDOCS 9803230317
Download: ML20248L629 (4)


See also: IR 05000313/1997021

Text

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NUCLEAR REGULATORY COMMISSION

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REGION IV

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611 RYAN PLAZA DRIVE, SUITE 400

ARLINGTON, TEXAS 76011-8064

March 18, 1998

EA 97-574

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C. Randy Hutchinson, Vice President

Operations

Arkansas Nuclear One

Entergy Operations, Inc.

1448 S.R. 333

Russellville, Arkansas 72801-0967

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SUBJECT:

NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-313/97-21;

50-368/97-21)

Dear Mr. Hutchinson:

This is in reference to the predecisional enforcement conference conducted with you and other

Entergy Operations, Inc., representatives on February 20,1998, in the NRC's Arlington, Texas,

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office. The conference was conducted to discuss three apparent violations of NRC

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requirements identified at the Arkansas Nuclear One, Unit 1, plant. The apparent violations

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were discussed in NRC Inspection Report 50-313/97-21; 50-368/97-21, issued February 6,

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1998, and were associated with events beginning December 4,1996, when the pressure and

vacuum relief valve on the borated water storage tank was removed for maintenance and

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testing.

The three apparent violations were: (1) failure to adequately evaluate the safety concerns

related to the borated water storage tank vacuum relief valve flange temporary coverings under

10 CFR 50.59; (2) failure to initiate the proper design control measures in accordance with

10 CFR Part 50, Appendix B, Criterion Ill, " Design Control"; and (3) failure to follow the vacuum

relief valve test procedure in accordance with 10 CFR Part 50, Appendix B, Criterion V,

" Instructions, Procedures, and Drawings."

Based on information provided during the conference, the NRC has determined that violations of

NRC requirements occurred, although the characterizations of these violations were changed

from the apparent violations presented in NRC Inspection Report 50-313/97-21; 50-368/97-21.

The first violation cited in the attached Notice of Violation (Notice) involves a failure to follow the

temporary alteration procedure. The inspection report identified this issue as an apparent

violation of 10 CFR Part 50, Appendix B, Criterion Ill, " Design Control," but the NRC has

concluded that this issue is more appropriately considered as a violation of 10 CFR Part 50,

Appendix B, Criterion V, " Instructions, Procedures, and Drawings." During the conference,

Entergy Operations, Inc., showed that its failure to follow the temporary alteration procedure

directly caused the failure to perform safety evaluations required by 10 CFR 50.59. Accordingly,

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no violation of 10 CFR 50.59 is being cited, since it is subsumed in the above violation.

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Entergy Operations, Inc.

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E-Mail report to T. Frye (TJF)

E-Mail report to T. Hiltz (TGH)

E-Mail report to NRR Event Tracking System (IPAS)

E-Mail report to Document Control Desk (DOCDESK)

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Regional Administrator

Resident inspector

DRS Director

DRS Deputy Director

DRP Director

MIS System

Branch Chief (DRP/C)

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Project Engineer (DRP/C)

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Branch Chief (DRPTTSS)

G. F. Sanborn, EO

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J. Lieberman, OE, MS: 7-H5

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OFFICIAL RECORD COPY

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Entergy Operations, Inc.

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The second violation cited in the Notice involves a separate violation of 10 CFR Part 50,

Appendix B, Criterion V, for the failure to have an adequate pressure and vacuum relief valve

test procedure for testing the pressure and vacuum relief valve during power operations.

During the conference, Entergy Operations, Inc., noted that its process for converting outage

activities to nonoutage was not adequate. As a result, the procedure, as written, did not provide

adequate guidance to assure that pressure and vacuum relief valve testing was conducted only

during a plant shutdown.

After consideration of the information provided during the predecisional enforcement conference,

the NRC has determined that the actual safety significance of these events was low. This

determination was based primarily on testing performed by Entergy Operations, Inc. This testing

demonstrated that under conditions accompanying a design basis accident, the plastic bag

surrounding the open pressure and vacuum relief valve flange would hr.ve failed within seconds,

thereby, preventing damage to the tank. Accordingly, the two violations referenced above have

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been categorized in'accordance with the " General Statement of Policy and Procedure for NRC

Enforcement Actions"(Enforcement Policy), NUREG-1600 at Severity LevelIV.

Despite designating these issues as Severity Level IV violations, the NRC remains concemed

that a considerable lapse in performance occurred in association with these events. It is

expected that actions will be taken to fully develop the causes for the failures that occurred and

that corrective actions commensurate with these findings will be implemented.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. The NRC will use your response, in part, to

determine 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, and your response will be placed in the NRC Public Document Room.

Sincerely,

VEs

choff

4

Regional Administrator

Docket Nos.: 50-313; 50-368

License Nos.: DPR-51; NPF-6

Enclosure: Notice of Violation

. cc:

Executive Vice President

& Chief Operating Officer

Entergy Operations, Inc.

P.O. Box 31995

Jackson, Mississippi 39286-1995

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Entergy Operations, Inc.

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Vice President

Operations Support

Eniergy Operations, Inc.

P.O. Box 31995

Jackson, Mississippi 39286

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

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, Mail Slot 30

Little Rock, Arkansas 72205-3867

Manager

Rockville Nuclear Licensing

Framatome Technologies

1700 Rockville Pike, Suite 525

Rockville, Maryland 20852

.