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Category:Letter type:
MONTHYEAR2CAN012401, U.S. Additional Protocol2024-01-17017 January 2024 U.S. Additional Protocol 2CAN012403, Supplemental Information - Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 42024-01-11011 January 2024 Supplemental Information - Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4 0CAN012401, Registration of Cask Use2024-01-10010 January 2024 Registration of Cask Use 1CAN122301, Responses to Request for Additional Information for Request for Alternative for Implementation of Extended Reactor Vessel Inservice Inspection Interval (ANO1-ISl-037)2023-12-14014 December 2023 Responses to Request for Additional Information for Request for Alternative for Implementation of Extended Reactor Vessel Inservice Inspection Interval (ANO1-ISl-037) 2CAN112302, Submittal of Amendment 31 to Safety Analysis Report2023-11-16016 November 2023 Submittal of Amendment 31 to Safety Analysis Report 0CAN102303, Registration of Cask Use2023-10-24024 October 2023 Registration of Cask Use 0CAN102302, (ANO) Emergency Plan Revision 49 and Emergency Plan On-Shift Staffing Analysis Revision 32023-10-11011 October 2023 (ANO) Emergency Plan Revision 49 and Emergency Plan On-Shift Staffing Analysis Revision 3 0CAN102301, Evacuation Time Estimate (ETE) Study2023-10-0404 October 2023 Evacuation Time Estimate (ETE) Study 1CAN092301, Supplemental Information - Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 42023-09-21021 September 2023 Supplemental Information - Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4 0CAN092302, Supplement to Request for Alternative Frequency to Containment Unbonded Post-Tensioning System Inservice Inspection (ANO-CISI-002)2023-09-14014 September 2023 Supplement to Request for Alternative Frequency to Containment Unbonded Post-Tensioning System Inservice Inspection (ANO-CISI-002) 2CAN092301, Reply to a Notice of Violation2023-09-0808 September 2023 Reply to a Notice of Violation 0CAN092301, Emergency Plan Implementing Procedure Revision2023-09-0505 September 2023 Emergency Plan Implementing Procedure Revision 0CAN082301, Units 1 and 2 - Changes to the Quality Assurance Program Approval Form for Radioactive Material Package No. 03412023-08-17017 August 2023 Units 1 and 2 - Changes to the Quality Assurance Program Approval Form for Radioactive Material Package No. 0341 2CAN082301, Inservice Inspection Summary Report for the Arkansas Nuclear One, Unit 2, Twenty-Ninth Refueling Outage (2R29)2023-08-10010 August 2023 Inservice Inspection Summary Report for the Arkansas Nuclear One, Unit 2, Twenty-Ninth Refueling Outage (2R29) 0CAN072301, Registration of Cask Use2023-07-18018 July 2023 Registration of Cask Use 1CAN062304, Supplement Related to License Amendment Request to Remove Technical Specification Condition Allowing Two Reactor Coolant Pump Operation2023-06-29029 June 2023 Supplement Related to License Amendment Request to Remove Technical Specification Condition Allowing Two Reactor Coolant Pump Operation 0CAN062301, Status of Actions to Return to Compliance2023-06-26026 June 2023 Status of Actions to Return to Compliance 0CAN062302, Submittal of Revision 22 of the ANO Fire Hazards Analysis2023-06-20020 June 2023 Submittal of Revision 22 of the ANO Fire Hazards Analysis 1CAN062301, Request for Alternative for Implementation of Extended Reactor Vessel Inservice Inspection Interval (ANO1-ISI-037)2023-06-0808 June 2023 Request for Alternative for Implementation of Extended Reactor Vessel Inservice Inspection Interval (ANO1-ISI-037) 0CAN052303, Annual 10 CFR 50.46 Report for Calendar Year 20222023-05-24024 May 2023 Annual 10 CFR 50.46 Report for Calendar Year 2022 0CAN052302, Emergency Plan Rev. 482023-05-11011 May 2023 Emergency Plan Rev. 48 0CAN052301, Units 1 and 2 - Annual Radiological Environmental Operating Report for 20222023-05-0909 May 2023 Units 1 and 2 - Annual Radiological Environmental Operating Report for 2022 2CAN052301, Cycle 30 Core Operating Limits Report (COLR)2023-05-0303 May 2023 Cycle 30 Core Operating Limits Report (COLR) 0CAN042302, Annual Occupational Radiation Exposure Report for 20222023-04-27027 April 2023 Annual Occupational Radiation Exposure Report for 2022 0CAN042301, Radioactive Effluent Release Report for 20222023-04-14014 April 2023 Radioactive Effluent Release Report for 2022 2CAN042301, License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 42023-04-0505 April 2023 License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4 1CAN032301, License Amendment Request to Modify the Arkansas Nuclear One, Unit 1, Technical Specification 3.3.1, Reactor Protection System Instrumentation, Turbine Trip Function on Low Control Oil Pressure2023-03-30030 March 2023 License Amendment Request to Modify the Arkansas Nuclear One, Unit 1, Technical Specification 3.3.1, Reactor Protection System Instrumentation, Turbine Trip Function on Low Control Oil Pressure 2CAN032303, Responses to Request for Additional Information Concerning the Request for Alternative Regarding the Half-Nozzle Repair of Reactor Vessel Closure Head Penetration 462023-03-29029 March 2023 Responses to Request for Additional Information Concerning the Request for Alternative Regarding the Half-Nozzle Repair of Reactor Vessel Closure Head Penetration 46 2CAN032304, Supplement to the Request for Alternative Regarding the Half-Nozzle Repair of Reactor Vessel Closure Head Penetration 462023-03-29029 March 2023 Supplement to the Request for Alternative Regarding the Half-Nozzle Repair of Reactor Vessel Closure Head Penetration 46 2CAN032305, 03 Post Examination Analysis2023-03-23023 March 2023 03 Post Examination Analysis 1CAN032302, Inspection Summary Report for the Thirtieth Refueling Outage (1R30)2023-03-20020 March 2023 Inspection Summary Report for the Thirtieth Refueling Outage (1R30) 1CAN012301, Responses to Request for Additional Information for Request for Relief ANO1-ISI-0352023-01-30030 January 2023 Responses to Request for Additional Information for Request for Relief ANO1-ISI-035 2CAN012303, U.S. Additional Protocol2023-01-23023 January 2023 U.S. Additional Protocol 2CAN012302, Relief Request ANO2-RR-23-001, Half-Nozzle Repair of Reactor Vessel Closure Head Penetration 462023-01-20020 January 2023 Relief Request ANO2-RR-23-001, Half-Nozzle Repair of Reactor Vessel Closure Head Penetration 46 1CAN122201, License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 42022-12-22022 December 2022 License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4 0CAN122202, Registration of Cask Use2022-12-21021 December 2022 Registration of Cask Use 0CAN122201, Reply to a Notice of Violation; EA-22-0992022-12-0808 December 2022 Reply to a Notice of Violation; EA-22-099 0CAN112201, Request for Alternative Frequency to Containment Unbonded Post-Tensioning System Inservice Inspection (ANO-CISI-002)2022-11-10010 November 2022 Request for Alternative Frequency to Containment Unbonded Post-Tensioning System Inservice Inspection (ANO-CISI-002) 1CAN102202, Application to Remove Technical Specification Condition Allowing Two Reactor Coolant Pump Operation2022-10-31031 October 2022 Application to Remove Technical Specification Condition Allowing Two Reactor Coolant Pump Operation 1CAN102203, Cycle 31 Core Operating Limits Report2022-10-24024 October 2022 Cycle 31 Core Operating Limits Report 1CAN102201, Supplement to Proposed Technical Specifications 3.4.12 and 3.4.13 Revised Dose Calculations2022-10-13013 October 2022 Supplement to Proposed Technical Specifications 3.4.12 and 3.4.13 Revised Dose Calculations 0CAN092201, Supplement to License Amendment Request for Approval of Changes to the Emergency Plan Staffing Requirements2022-09-29029 September 2022 Supplement to License Amendment Request for Approval of Changes to the Emergency Plan Staffing Requirements 1CAN092201, Supplement to Request for Relief from American Society of Mechanical Engineers Section XI Volumetric Examination Requirements - Fifth 10-Year Interval, First Period2022-09-0808 September 2022 Supplement to Request for Relief from American Society of Mechanical Engineers Section XI Volumetric Examination Requirements - Fifth 10-Year Interval, First Period 0CAN082201, License Amendment Request for Approval of Changes to the Emergency Plan Staffing Requirements2022-08-30030 August 2022 License Amendment Request for Approval of Changes to the Emergency Plan Staffing Requirements 1CAN082201, Request for Relief from American Society of Mechanical Engineers Section XI Volumetric Examination Requirements - Fifth 10-Year Interval, First Period2022-08-24024 August 2022 Request for Relief from American Society of Mechanical Engineers Section XI Volumetric Examination Requirements - Fifth 10-Year Interval, First Period 2CAN072201, Response to Request for Additional Information Requests for Relief from American Society of Mechanical Engineers Section XI Volumetric Examination Requirements - Fourth 10-Year Interval, Second and Third Periods2022-07-20020 July 2022 Response to Request for Additional Information Requests for Relief from American Society of Mechanical Engineers Section XI Volumetric Examination Requirements - Fourth 10-Year Interval, Second and Third Periods 0CAN072201, Registration of Cask Use2022-07-14014 July 2022 Registration of Cask Use 0CAN062202, Registration of Cask Use2022-06-0909 June 2022 Registration of Cask Use 1CAN062201, Response to the Request for Additional Information Proposed Technical Specifications 3.4.12 and 3.4.13 Revised Dose Calculations2022-06-0202 June 2022 Response to the Request for Additional Information Proposed Technical Specifications 3.4.12 and 3.4.13 Revised Dose Calculations 1CAN052201, Request for Relief Related to American Society of Mechanical Engineers (ASME) Code Case N-729-6 Augmented Examination Requirements ANO1-ISI-0352022-05-31031 May 2022 Request for Relief Related to American Society of Mechanical Engineers (ASME) Code Case N-729-6 Augmented Examination Requirements ANO1-ISI-035 2024-01-17
[Table view] Category:Licensee Response to Notice of Violation
MONTHYEAR2CAN092301, Reply to a Notice of Violation2023-09-0808 September 2023 Reply to a Notice of Violation 0CAN122201, Reply to a Notice of Violation; EA-22-0992022-12-0808 December 2022 Reply to a Notice of Violation; EA-22-099 ML20239B0482020-07-31031 July 2020 RSP_IA-20-028_Johnson ML20239B0472020-07-31031 July 2020 RSP_IA-20-029_Spivey 2CAN031703, Reply to a Notice of Violation; EA-16-2472017-03-29029 March 2017 Reply to a Notice of Violation; EA-16-247 0CAN091501, Units 1 and 2, Response to Non-cited Violation in NRC Integrated Inspection Report 05000313/2015002 and 05000368/20150022015-09-0303 September 2015 Units 1 and 2, Response to Non-cited Violation in NRC Integrated Inspection Report 05000313/2015002 and 05000368/2015002 0CAN021504, Reply to Notice of Violation; EA-14-0882015-02-23023 February 2015 Reply to Notice of Violation; EA-14-088 0CAN071402, Units 1 and 2, Reply to Notice of Violation; EA-14-0082014-07-18018 July 2014 Units 1 and 2, Reply to Notice of Violation; EA-14-008 0CAN041301, Units 1 and 2: Response to an Apparent Violation in Inspection Report Nos. 05000313-13-503 and 05000368-13-503; EA-12-2752013-04-10010 April 2013 Units 1 and 2: Response to an Apparent Violation in Inspection Report Nos. 05000313-13-503 and 05000368-13-503; EA-12-275 0CAN011101, Reply to Notice of Violation, EA-10-2332011-01-10010 January 2011 Reply to Notice of Violation, EA-10-233 2023-09-08
[Table view] |
Text
- ) entergy Riley D. Keele, Jr.
Manager, Regulatory Assurance Arkansas Nuclear One Tel 479-858-7826 10 CFR 2.201 0CAN122201 December 8, 2022 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Reply to a Notice of Violation; EA-22-099 Arkansas Nuclear One, Units 1 and 2 NRC Docket Nos. 50-313 and 50-368 Renewed Facility Operating License Nos. DPR-51 and NPF-6
Reference:
NRC letter to Entergy, "Notice of Violation, NRC Inspection Report 05000313/2022011 and 05000368/2022011," (0CNA 112203) (ML22301A153),
dated November 9, 2022
Dear Sir or Madam:
By the reference above, the NRC issued Entergy Operations, Inc. (Entergy) a green Notice of Violation (NOV) for Arkansas Nuclear One (ANO) for failure to manage the effects of aging on the buried Unit 1 and Unit 2 Service Water supply piping as required by regulatory requirements. Specifically, when managing the effects of aging, the licensee has not performed thickness measurements of its buried in-scope Emergency Cooling Pond supply piping and provided reasonable assurance that the Service Water system remains capable of performing its design function. The NOV requires a written response within 30 days addressing the following: reason for the violation, corrective steps that have been taken and results achieved, corrective steps that will be taken, and date when full compliance will be achieved. Enclosure 1 provides Entergy's response to the NOV.
The new commitments contained in this submittal are provided in Enclosure 2.
Should you have any questions, please contact Mr. Riley Keele at 479-858-7826.
Respectfully, lc~~4-RDK/ble Entergy Operations, Inc. 1448 SR 333, Russellville, AR 72802
0CAN122201 Page 2 of 2
Enclosures:
- 1. Response to Notice of Violation
- 2. List of Regulatory Commitments cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - Arkansas Nuclear One NRC Project Manager - Arkansas Nuclear One R4Enforcement@nrc.gov
Enclosure 1 0CAN122201 Response to Notice of Violation
0CAN122201 Page 1 of 3 Response to Notice of Violation Description of Violation:
Failure to Perform Required Thickness Measurements as Required by Design to Manage the Effects of Aging Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.5] - Work 71003 Systems VIO 05000313,05000368/2022011-01 Management Open EA-22-099 The team identified a green finding and associated Notice of Violation because the licensee failed to manage the effects of aging on the buried unit 1 and unit 2 service water supply piping as required by regulatory requirements. Specifically, the licensee failed to measure pipe wall thickness to assess the condition of the supply piping that provides cooling during a design basis accident.
Entergy documented the violation in its Corrective Action Program and a causal analysis was performed to identify and correct the underlying causes for this failure.
Reason for the violation:
Inspection plans scheduled in previous refueling outages were inappropriately deferred due to an inadequate understanding and application of the applicable regulatory requirements. Causal factors contributing to this include:
Previous changes to program owner alignment and responsibilities in the Microbiologically Influenced Corrosion (MIC) and Buried Piping programs.
This led to gaps in the advocacy and ownership of the applicable regulatory-related inspection requirements for the Unit 1 and Unit 2 Emergency Cooling Pond (ECP) supply piping.
Inadequate management oversight led to inspection deferrals. The Arkansas Nuclear One (ANO) Plant Health Committee did not provide effective oversight of the project established to replace the Emergency Cooling Pond supply piping. This resulted in deferral of the required inspections to support the project without an adequate regulatory basis to support the deferral.
Improper justification of aging management barriers. Comparison data related to non-chemically treated piping was utilized as inappropriate justification for deferring the inspections for the Emergency Cooling Pond supply piping. Additionally, programmatic inspection points were removed from the ANO MIC program in 2021 for unknown reasons or justification.
0CAN122201 Page 2 of 3 Corrective steps that have been taken and results achieved:
During the ANO Unit 1 (ANO-1) fall 2022 refueling outage (1R30), Entergy performed non-destructive examination (NDE) of the Service Water Emergency Cooling Pond supply piping utilizing automated ultrasonic testing (AUT). The results of the AUT showed that no indications were observed below the critical thickness acceptance criteria. In addition, the remaining service life calculation shows that NDE inspections should be performed within ten years to establish a new remaining service life or determine a need for piping replacement. This inspection would need to occur prior to 1R36 which is currently scheduled in 2031.
Plant Health Committee weaknesses were addressed early in 2022 to improve oversight of the deferral of projects by ensuring the basis for the deferral was acceptable and that any bridging strategy needs were appropriately implemented.
Corrective steps that will be taken:
During the upcoming ANO Unit 2 (ANO-2) spring 2023 refueling outage (2R29), Entergy plans to perform NDE of the ANO-2 Service Water Emergency Cooling Pond buried supply piping. The inspection results will be used to establish a remaining service life, determine if replacement activities are required, and establish re-inspection intervals to determine a new remaining service life.
The ANO MIC Program (SEP-MIC-ANO-001) is being revised to provide clarification and confirmation that MIC-susceptible buried piping will be included in future inspection scope. This clarity will ensure inspection requirements are understood and that unexpected turnovers of program ownership will be appropriately mitigated by explicit program guidance. Additionally, information contained in ANO Engineering Report CALC-A-EP-2005-001 ANO MIC Program is being reviewed for inclusion into SEP-MIC-ANO-001 in order to have only one programmatic controlling document for the MIC Program. Conflicting and unclear guidance between these two documents challenged a thorough understanding of the required program inspections.
MIC program qualification requirements will be completed for the current MIC Program Owner and a backup engineer. Previous unexpected program owner turnover and transfer of responsibilities led to inadequate advocacy and ownership of the program requirements due to filling the program owner vacancies with personnel with little experience or knowledge of the MIC program.
Date when full compliance will be achieved:
Full compliance will be achieved by completion of the 2R29 refueling outage, scheduled for spring of 2023, once the following actions have been completed:
MIC Program (SEP-MIC-ANO-001) is revised to provide clarification and confirmation that MIC-susceptible buried piping will be included in the inspection scope.
0CAN122201 Page 3 of 3 MIC Program owner and backup have completed their qualifications.
NDE inspection of the ANO-2 ECP supply piping is performed during the spring 2023 refueling outage. This will ensure thickness data has been captured for both ANO-1 and ANO-2 ECP supply piping, providing the basis for continued service life of this piping and/or required repair or replacement activities.
Enclosure 2 0CAN122201 List of Regulatory Commitments
0CAN122201 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy Operations, Inc. (Entergy) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
TYPE SCHEDULED (Check One) COMPLETION COMMITMENT ONE-TIME CONTINUING DATE ACTION COMPLIANCE (If Required)
Entergy will revise the Microbiological Influenced Corrosion Program (SEP-MIC-ANO-001) to provide X March 17, 2023 clarification and confirmation that MIC-susceptible buried piping will be included in future inspection scope.
MIC program qualification requirements will be completed for the X April 14, 2023 current MIC Program owner and a backup engineer.
Entergy will perform a non-destructive examination inspection of the Arkansas Nuclear One, Unit 2 X End of 2R29 Emergency Cooling Pond supply piping during the upcoming 2R29 refueling outage.