IR 05000313/2023002
| ML23221A301 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear |
| Issue date: | 08/11/2023 |
| From: | John Dixon NRC/RGN-IV/DORS/PBD |
| To: | Pehrson D Entergy Operations |
| References | |
| IR 2023002 | |
| Download: ML23221A301 (41) | |
Text
August 11, 2023
SUBJECT:
ARKANSAS NUCLEAR ONE - INTEGRATED INSPECTION REPORT 05000313/2023002 AND 05000368/2023002 AND NOTICE OF VIOLATION
Dear Doug Pehrson:
On June 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Arkansas Nuclear One. On July 13, 2023, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
The enclosed report discusses a violation associated with a finding of very low safety significance (Green), for the failure to ensure that conditions adverse to quality, involving failures of emergency feedwater steam supply check valves, were promptly identified and corrected. The NRC evaluated this violation in accordance section 2.3.2 of the NRC Enforcement Policy, which can be found at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. We determined that this violation did not meet the criteria to be treated as a non-cited violation because the violation had been previously identified in 2018, and failures continue to occur for Unit 2, indicating compliance has not been restored within a reasonable period of time.
You are required to respond to this letter and should follow the instructions specified in the Notice of Violation when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response. The NRCs review of your response will also determine whether further enforcement action is necessary to ensure your compliance with regulatory requirements.
Additionally, two findings of very low safety significance (Green) are documented in this report.
These findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with section 2.3.2 of the Enforcement Policy. If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Arkansas Nuclear One.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Arkansas Nuclear One.
This letter, its enclosure, and your response will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Signed by Dixon, John on 08/11/23
John L. Dixon, Jr., Chief Reactor Projects Branch D Division of Operating Reactor Safety
Docket Nos. 05000313, 05000368 License Nos. DPR-51, NPF-6
Enclosure:
1. Notice of Violation 2. Inspection Report 05000313/2023002 and 05000368/2023002
Inspection Report
Docket Numbers:
05000313 and 05000368
License Numbers:
Report Numbers:
05000313/2023002 and 05000368/2023002
Enterprise Identifier: I-2023-002-0007
Licensee:
Entergy Operations, Inc.
Facility:
Arkansas Nuclear One
Location:
Russellville, AR
Inspection Dates:
April 1, 2023, to June 30, 2023
Inspectors:
D. Antonangeli, Health Physicist
R. Azua, Senior Reactor Inspector
N. Brown, Resident Inspector
R. Bywater, Senior Resident Inspector
T. DeBey, Resident Inspector
N. Greene, Senior Health Physicist
J. O'Donnell, Senior Health Physicist
Approved By:
John L. Dixon, Jr., Chief
Reactor Projects Branch D
Division of Operating Reactor Safety
Enclosure 2
2-2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Arkansas Nuclear One, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Properly Evaluate a Replacement Motor-Operated Valve Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000313/2023002-01 Open/Closed
[H.12] - Avoid Complacency 71111.18 The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to evaluate all aspects of several service water boundary valve replacement motor-operated valves (MOVs). Specifically, modification engineering change 85805 installed a new, Unit 1, loop 2 service water-to-intermediate cooling water isolation valve CV-3811, which had a thicker actuator mounting plate than the original valve but reused the original fasteners in the final installation. Consequently, the installed actuator mounting fasteners did not meet thread engagement requirements.
Failure to Perform Air Sampling Analysis Resulting in Two Uptakes Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000368/2023002-02 Open/Closed
[H.1] -
Resources 71124.04 The inspectors reviewed a self-revealed Green, non-cited violation of Technical Specification 6.4.1 for the licensee's failure to follow procedures to assess an air sample prior to a job activity. Specifically, the licensee failed to analyze an air sample prior to filter changeouts resulting in two workers receiving unintended exposure to airborne radioactivity (i.e., an uptake).
Failure to Establish Adequate Corrective Actions Resulting in Excessive Instances of Damaged and Broken Internals of the Emergency Feedwater Pump Turbine Steam Admission Check Valves Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NOV 05000368/2023002-03 Open
[H.6] - Design Margins 71152A The inspectors identified a Unit 2 Green finding and associated Notice of Violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the failure to promptly identify and correct a condition adverse to quality. Specifically, the licensee failed to correct in a timely manner the deficient system design of the check valves admitting steam to the emergency feedwater turbine.
2-3
PLANT STATUS
Unit 1 began the inspection period at full power. On May 25, 2023, Unit 1 operators reduced power to 98.8 percent following a failure of circulating water pump B. Failure of circulating water pump B resulted in only 2 out of 4 circulating water pumps remaining functional, because circulating water pump D remained out of service for repairs following a failure it sustained on February 10, 2023. Operators returned power to 100 percent on May 26, 2023. Unit 1 continued operating at or near full power until June 30, 2023, when Unit 1 operators reduced power to approximately 96 percent because elevated lake temperatures exceeded the capability of the unit to operate at full power with only two circulating water pumps in operation.
Unit 2 began the inspection period operating at approximately 88 percent power in an end-of operating cycle power coast down. Unit 2 operators removed the unit from service on April 14, 2023, to begin refueling outage 2R29. Following the refueling outage, Unit 2 operators restarted the reactor on May 22, 2023, placed the unit online on May 23, 2023, and returned the unit to 100 percent power on May 26, 2023. On June 14, 2023, Unit 2 operators manually tripped the B main feedwater pump in response to an electrohydraulic control fluid leak on the pump turbine, which stopped the leak and initiated a turbine runback. Reactor power was reduced to approximately 79.2 percent and stabilized at approximately 80 percent power while repairs were made to an electrohydraulic control fluid fitting. After repairs were completed, Unit 2 operators raised power to 100 percent the same day. On June 14, 2023, Unit 2 operators identified symptoms of failure of the A main feedwater pump and initiated a rapid power reduction. The operators stabilized power at approximately 75 percent. The cause of the main feedwater pump A failure was failure of the turbine-to-pump coupling. Following completion of repairs, Unit 2 operators returned the unit to 100 percent power on June 17, 2023. Unit 2 remained at or near full power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
2-4
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)alternate AC diesel generator after loss of London line (13.8 kV) and restoration activities on June 20, 2023
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 1 turbine-driven emergency feedwater system on June 28, 2023.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Unit 2 electrical class 1E cable spreading room, fire zone 2108-S, on May 23, 2023
- (2) Unit 1 class 1E A3 4160 Vac switchgear, fire zone 100-N, on May 23, 2023
- (3) Unit 1 turbine building, fire zone 197-X, on May 31, 2023
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) Unit 2 shutdown cooling heat exchangers 2E-35A and 2E-35B on April 25, 2023
===71111.08P - Inservice Inspection Activities (PWR) The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined, and accepted by reviewing the following activities from April 16, 2023, to April 28, 2023.
PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01)===
The inspectors verified that the following nondestructive examination and welding activities were performed appropriately:
(1)
- Chemical Volume and Control System (Charging) 2CCA-26, ID 41-008, Pipe to Elbow Circumferential Weld (UT)
2-5
- Low Pressure Safety Injection System 2CCA-22-1, ID 2-22-001A, Elbow to Pipe Circumferential Weld (UT)
- Low Pressure Safety Injection System 2CCA-22-1, ID 2-22-003, Pipe from Check Valve 2SI-15A to Elbow Circumferential Weld (UT)
- Chemical Volume and Control System (Charging) 2CCA-27-4, ID 40-059, One Way Small Pipe Restraint for Charging Inlet from Regenerative Heat Exchanger (VT-3)
- Service Water to Emergency Diesel Jacket Cooler 2E20B, ID 2-73-044W, Integrally Welded Pipe Support Attachment 2HBC-64-H9 (VT-1 & VT-3)
- Safety Injection and Shutdown Cooling to RCP C 2CCA-24, ID 23-069, Anchor for Pipe 2CCA-24-H22 (PT)o Weld package reviewed: Reviewed licensee historical weld package related to Safety Injection System Pipe Anchor 23-069 and reviewed licensee evaluation of indications identified in the dye penetrant testing, and actions taken by the licensee
- Service Water 2HBC-34, ID FW-016, Pipe Weld (MT)
PWR Inservice Inspection Activities Sample - Vessel Upper Head Penetration Inspection
Activities (IP Section 03.02) (1 Sample)
The inspectors verified that the licensee conducted the following vessel upper head penetration inspections and addressed any identified defects appropriately:
- (1) The inspector observed the setup of visual, ultrasonic and eddy current examination equipment to be used for the inspection of the reactor vessel upper head and associated penetrations, and monitored the collection of data for the examination activities, which consisted of a bare metal visual examination of the reactor vessel head surface and penetrations, and subsequent ultrasonic and eddy current examination of selected CRDM nozzles.
PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03) (1 Sample)
The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following evaluations:
(1)
- CR-ANO-2-2022-00179; CR-ANO-2-2022-00383; CR-ANO-2-2022-00529; CR-ANO-2-2022-01378; CR-ANO-2-2023-00297
PWR Inservice Inspection Activities Sample - Steam Generator Tube Inspection Activities (Section 03.04) (1 Sample)
The inspectors verified that the licensee is monitoring the steam generator tube integrity appropriately through a review of the following examinations:
(1)
- no steam generator tube inspections were scheduled or performed during this refueling outage
2-6
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during Unit 2 transition to shutdown cooling and mode change to cold shutdown on April 15, 2023.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)
- (1) The inspectors observed and evaluated the Dynamic examination (steam generator fault, plant trip, overcooling event, main steam isolation) for Unit 2, crew E, on June 21, 2023.
- (2) The inspectors observed and evaluated the security event requalification training for Unit 1, crew D, on June 27, 2023.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Unit 1 service water valve CV-3811 on April 7, 2023, after failure on February 11, 2023
Aging Management (IP Section 03.03) (1 Sample)
The inspectors evaluated the effectiveness of the aging management program for the following SSCs that did not meet their inspection or test acceptance criteria:
- (1) Unit 2 thickness measurement of an excavated portion of buried service water piping from the emergency cooling pond completed on May 11, 2023
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 2 elevated risk due to failures of circulating water pumps P-3B and P-3D on May 31, 2023
- (2) Unit 1 and Unit 2 elevated risk due to planned maintenance on startup transformer 2 on June 14, 2023
- (3) Unit 1 and Unit 2 elevated risk due to planned maintenance on the alternate ac generator with Pleasant Hill 161 kV offsite transmission line unavailable on June 26, 2023
2-7
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 1 operability of service water pump P-4A after motor replacement and pump performance outside of expected band as documented in work orders 455328 and 52983646 on April 19, 2023 (2)functionality of fire barrier penetration FB-175-4-0098 after as found degraded condition on April 24, 2023 (3)functionality of fire barrier penetration FB-2048-05-0124 after as found degraded condition on April 26, 2023
- (4) Unit 2 plant protection system response time test channel B after failed surveillance on May 21, 2023
- (5) Unit 2 containment high range radiation monitor 2RE-8925-2 as-installed cable bending radius on May 24, 2023
- (6) Unit 2 safety injection tank B operability determination due to inventory leakage on June 20, 2023
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (4 Samples)
The inspectors evaluated the following temporary or permanent modifications:
(1)temporary modification to add alternate power source to Unit 2 spent fuel pool cooling pumps per work order 568997 on May 9, 2023 (2)temporary modification to provide a plate-type heat exchanger, spent fuel pool cooling system per work order 539568 on May 11, 2023 (3)temporary modification to add alternate startup channel to Unit 2 for fuel movements in reactor vessel per work order 574775 on May 16, 2023 (4)permanent modification to replace Unit 1 service water-to-intermediate cooling water isolation valve CV-3811, per engineering change 85805, on June 29, 2023
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated Unit 2 refueling outage 29 activities from April 14 to May 23, 2023.
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (5 Samples)
- (1) Unit 1 service water valve CV-3811 following repair on April 4, 2023
2-8
- (2) Unit 2 containment high range rad monitor 2RITS-8925-1 after identification of errors in the calibration and site testing procedure on April 7, 2023
- (3) Unit 2 high-pressure safety injection valve 2SI-27A following component replacement on May 24, 2023
- (4) Unit 2 high-pressure safety injection valve 2SI-28A following component replacement on May 24, 2023
- (5) Unit 2 plant protection system channel C variable trip module for steam generator level following replacement on June 2, 2023
Surveillance Testing (IP Section 03.01) (6 Samples)
(1)diesel fire water pump P-6B surveillance on May 4, 2023
- (2) Unit 2 main steam safety valves surveillance on May 11, 2023
- (3) FLEX Hale pump P-255 (Unit 1 steam generator/reactor coolant system makeup)surveillance on May 16, 2023
- (4) Unit 2 main turbine speed detection module overspeed surveillance test on May 21, 2023
- (5) Unit 2 main turbine diverse overspeed protection module surveillance test on May 21, 2023
- (6) Unit 2 emergency-powered pressurizer heater capacity surveillance on May 25, 2023
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) Unit 2 testing of lower pressure safety injection valve 2CV-5037-1, per work order 52956635, on June 28, 2023
Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)
- (1) Unit 2 testing of containment isolation valve 2CV-5650-2 per work order 52996885, on June 9, 2023
Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)
- (1) FLEX 800 kw diesel generator (K12) periodic testing on April 27,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.
2-9
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
(1)observed survey and control of potentially contaminated material leaving the radiologically controlled area, specifically the transport of a reactor coolant pump motor out of the Unit 2 equipment hatch (2)observed workers exiting the Unit 2 containment building during a refueling outage
Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
(1)entries under the Unit 2 reactor vessel head for manual non-destructive examinations using radiation work permit (RWP) 2023-02471, revision 00 (2)removal of the 2P-32A reactor coolant pump seals using RWP 2023-02465, revision 00 (3)initial entry survey of the refueling water storage tank interior under RWP 2023-02474, revision 00
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)
The inspectors evaluated licensee controls of the following high radiation areas (HRA) and very high radiation areas:
(1)
(HRA) the diversified skid and the 2T-20A/B tank rooms on the Unit 2 auxiliary building 317-foot elevation (2)
(HRA) 2T-5 and 2T-15 tank rooms and 2F-3A/B and 2F-4A/B rooms on the Unit 2 auxiliary building 335-foot elevation (3)
(HRA) radwaste crane ladder in the low-level radioactive waste building (4)
(HRA) reactor coolant piping hot leg penetration on the Unit 2 reactor building 369-foot elevation (5)
(HRA) reactor vessel head stand on the Unit 2 reactor building 404-foot elevation
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.
2-10
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.
Internal Dosimetry (IP Section 03.03) (3 Samples)
The inspectors evaluated the following internal dose assessments:
(1)personnel contamination event (PCE) 2022-009, and its associated whole body count assessment, October 21, 2022
- (2) PCE 2022-011, and its associated whole body count assessment, December 24, 2022
Special Dosimetric Situations (IP Section 03.04) (3 Samples)
The inspectors evaluated the following special dosimetric situations:
(1)effective dose equivalent (EDEX) multipack dosimetry assignment for radiation work permit (RWP) 2021-2430, RWP 2021-2471, RWP 2022-1502, and RWP 2023-2471
- (2) NRC Form 5 for five workers using EDEX multipack dosimetry
- (3) NRC Form 5 for three declared pregnant workers
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (2 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) SPING-4 on the Unit 1 auxiliary building 354-foot elevation (2)area radiation monitor RE-8912 on the Unit 1 auxiliary building 354-foot elevation
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Walkdowns and Observations (IP Section 03.01) (5 Samples)
The inspectors evaluated the following radioactive effluent systems during walkdowns:
- (1) Unit 1 liquid radioactive waste system
- (2) Unit 2 liquid radioactive waste system
- (3) Unit 2 fuel handling area ventilation system
- (4) Unit 2 reactor building purge system
- (5) Unit 1 penetration room ventilation system
2-11
Sampling and Analysis (IP Section 03.02) (4 Samples)
Inspectors evaluated the following effluent samples, sampling processes and compensatory samples:
- (1) June 13, 2023, gaseous effluent, tritium, charcoal and particulate sample for Unit 2 auxiliary building (2RX-9825 - SPING 6)
- (2) June 13, 2023, gaseous effluent, tritium, charcoal and particulate sample for Unit 2 spent fuel pool area (2RX-9830 - SPING 7)
- (3) June 13, 2023, charcoal and particulate sample for Unit 2 emergency penetration room (2RX-9835 - SPING 8)
- (4) June 14, 2023, liquid effluent sample for Unit 1 neutralizing tank (T50)
Dose Calculations (IP Section 03.03) (2 Samples)
The inspectors evaluated the following dose calculations:
(1)dose calculations associated with liquid radioactive release permits: 1LR2020-0050, 1LR2021-0018, 1LR2022-0028, 1LR2023-0016, 2LR2020-0025, 2LR2021-0028, 2lR2022-0009, 2LR2023-0002 (2)dose calculations associated with gaseous radioactive release permits:
1GR2020-0092, 1GR2021-0029, 1GR2022-0049, 1GR2023-0002, 2GR2020-0030, 2GR2021-0097, 2GR2022-0028,2GR2023-0036
Abnormal Discharges (IP Section 03.04) (2 Samples)
The inspectors evaluated the following abnormal discharges:
- (1) On March 28, 2020, air was unexpectedly released through an unmonitored pathway for 48 minutes. Air samples were obtained and a release permit (2GR2020-0030) was generated to document the abnormal release of tritium through the open roof hatch.
- (2) On February 9, 2023, there was an unplanned release of air for 270 minutes through door 94 as workers changed out carbon filters for the Unit 1 fuel handling area exhaust ventilation system. Radiation protection personnel notified Chemistry and took air samples as directed. A release permit (1GR2023-0002) was generated to document the unplanned release.
71124.07 - Radiological Environmental Monitoring Program
Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples.
Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.
2-12
GPI Implementation (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees implementation of the Groundwater Protection Initiative program to identify incomplete or discontinued program elements.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
- (1) Unit 1 (April 1, 2022, through March 31, 2023)
- (2) Unit 2 (April 1, 2022, through March 31, 2023)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)
- (1) Unit 1 (April 1, 2022, through March 31, 2023)
- (2) Unit 2 (April 1, 2022, through March 31, 2023)
BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)
- (1) Unit 1 (April 1, 2022, through March 31, 2023)
- (2) Unit 2 (April 1, 2022, through March 31, 2023)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) Unit 1 and Unit 2 (October 1, 2022, through March 31, 2023)
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) Unit 1 and Unit 2 (October 1, 2022, through March 31, 2023)
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) The inspectors reviewed the licensees corrective action program for motor-operated valves (both Limitorque and Rotork) on both units. The review included problems identified with Unit 2 high pressure safety injection valve 2CV-5036-2, Unit 1 service water control valve CV-3811, and Unit 2 containment sump isolation valve 2CV-5650-2.
- (2) The inspectors reviewed the licensees corrective action program for discrepancies in the fire hazards analysis related to actual plant configuration of fire dampers.
- (3) The inspectors reviewed the licensees corrective action program for long term corrective actions associated with the failure of emergency feedwater steam supply
2-13
- (4) The inspectors reviewed the licensees corrective action program for the sites control of ladders and their materials of construction.
71153 - Follow Up of Events and Notices of Enforcement Discretion Personnel Performance (IP section 03.03)
- (1) The inspectors evaluated the licensees performance in response to an electrohydraulic fluid leak at the Unit 2, main feedwater pump B, manual trip of the pump, turbine runback and rapid power reduction to approximately 79 percent power on June 14, 2023.
- (2) The inspectors evaluated the licensees performance in response to a turbine-to-pump coupling failure on the Unit 2, main feedwater pump A, turbine runback and rapid power reduction to approximately 75 percent power on June 15,
INSPECTION RESULTS
Failure to Properly Evaluate a Replacement Motor-Operated Valve Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000313/2023002-01 Open/Closed
[H.12] - Avoid Complacency 71111.18 The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to evaluate all aspects of several service water boundary valve replacement motor-operated valves (MOVs). Specifically, modification engineering change 85805 installed a new, Unit 1, loop 2 service water-to-intermediate cooling water isolation valve CV-3811, which had a thicker actuator mounting plate than the original valve but reused the original fasteners in the final installation. Consequently, the installed actuator mounting fasteners did not meet thread engagement requirements.
Description:
The ANO Unit 1 service water system provides shared cooling water flow to safety-related and non-safety-related heat loads. The system has boundary isolation valves that automatically close on an engineered safeguards actuation signal to isolate nonessential loads during an accident. Loop 2 service water-to-intermediate cooling water isolation valve CV-3811, is a 14 inch butterfly valve that has an active safety function to automatically close on an engineered safeguards actuation signal and provide the isolation boundary between the safety-related loop 2 service water loads required during an accident and the non-safety-related intermediate cooling water system. The licensee prepared modification engineering change (EC) 85805 to replace several service water boundary valves, including valve CV-3811, with an upgraded valve design with greater maximum allowable stem torque and lower minimum-required torque. The EC allowed the re-use of the original Limitorque SMB-000 actuator and HBC gearbox. The licensee replaced the valve in the plant during refueling outage 1R30 in 2022.
During the inspectors review of an unrelated maintenance issue with this valve, the inspectors noticed in the field that the actuator mounting bolts which fastened the CV-3811 valve body to its actuator, had significantly less thread engagement than valve CV-3820, redundant loop 1 service water-to-intermediate cooling water boundary valve. Valve CV-3820 was scheduled to be replaced in a future refueling outage. The actuator mounting fasteners
2-14
for valve CV-3820 were flush with the top of its actuator gearbox flange whereas the fasteners for valve CV-3811 were not. The inspectors reviewed Procedure EN-MA-145, Maintenance Standard for Torque Applications, revision 11, which defined full thread engagement as follows: A fastener with the threads flush with the top of the nut. Note: 1-2 threads above the top of the nut is preferred. For studs installed in blind holes, a minimum of one stud diameter engagement in steel and two times stud diameter engagement for aluminum is required. Based on observations in the field, the inspectors noted the actuator mounting fasteners were not flush with the top of the steel actuator gearbox flange and did not appear to have at least one stud diameter of engagement with the gearbox flange. Based on the inspectors concern, the licensee entered this issue into their corrective action program as condition report CR-ANO-1-2023-00554. The licensee confirmed that the original 3/4 inch x 1 1/2 inch hex head cap screws were used in the installation of the new CV-3811 valve, and that the actuator mounting plate was approximately double the thickness of the original installation, resulting in approximately 1/2 inch fastener engagement to the actuator gearbox.
The licensee promptly initiated a work order and replaced the fasteners with ones of sufficient length to meet the procedure EN-MA-145 thread engagement requirements.
During the inspectors review of modification EC 85805, the inspectors noticed that the difference in actuator mounting plate thickness was not evaluated. Therefore, the licensee failed to identify that longer fasteners were required to meet the thread engagement requirements.
The licensee completed an engineering evaluation, including a thread engagement analysis of the as-found condition. The licensee was able to show that the required length of thread engagement to resist seismic design basis earthquake loads was 0.108 inch. Therefore, the licensees evaluation reasonably determined that the as-found thread engagement would not adversely affect operability of valve CV-3811.
Corrective Actions: The licensee promptly replaced valve CV-3811 fasteners with ones of sufficient length to meet the procedure EN-MA-145 thread engagement requirements and completed a thread engagement analysis to determine that valve CV-3811 was operable in the as-found condition. The licensee also completed an extent of condition review of other safety-related butterfly valves. The licensee identified five additional valves whose fasteners were not flush with the top of their actuator gearbox mounting flanges. However, in each case, the fasteners had greater than one stud diameter of engagement.
Corrective Action References: condition reports CR-ANO-1-2023-00554 and CR-ANO-1-2023-00960
Performance Assessment:
Performance Deficiency: The licensees failure to evaluate that a replacement valve, with a thicker actuator mounting plate, required longer actuator mounting fasteners to achieve full thread engagement, was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the as-found thread engagement for loop 2 service water-to-intermediate cooling water isolation valve CV-3811, actuator mounting fasteners did not meet the licensees definition of full thread engagement contained in procedure EN-MA-145, which
2-15
resulted in reasonable doubt about the modified valves seismic qualifications. The licensee corrected the condition and completed an engineering evaluation that determined the as-found condition did not adversely affect seismic qualification of the valve.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. In accordance with IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, issued November 30, 2020, the finding is of Green significance. The finding is a deficiency affecting the design or qualification of a mitigating structure, system, or component (valve CV-3811), but the valve maintained its operability and probabilistic risk assessment (PRA) functionality. Additionally, the finding did not involve external events mitigating systems, the reactor protection system, fire brigade, or flexible coping strategies.
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, during development of modification EC 85805, the licensee had determined the original actuator and gearbox were acceptable for use and assumed it was also acceptable to use the same fasteners.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires in part, measures shall be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems, and components.
Contrary to the above, from April 13, 2021 (the approval date of modification EC 85805)through April 3, 2023 (when the condition was corrected), measures were not established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems, or components. Specifically, the licensee failed to establish measures for the selection and review for suitability of application of service water valve fasteners that are essential for Unit 1, loop 2 service water-to-intermediate cooling water isolation valve CV-3811, to close and ensure adequate service water system flow for completing the systems safety-related functions.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
Failure to Perform Air Sampling Analysis Resulting in Two Uptakes Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000368/2023002-02 Open/Closed
[H.1] -
Resources 71124.04 The inspectors reviewed a self-revealed Green, non-cited violation of Technical Specification 6.4.1 for the licensee's failure to follow procedures to assess an air sample prior to a job activity. Specifically, the licensee failed to analyze an air sample prior to filter changeouts resulting in two workers receiving unintended exposure to airborne radioactivity (i.e., an uptake).
2-16
Description:
On April 3, 2023, radiation protection (RP) staff provided support to the maintenance staff during changeout of filters 2F-3A and 2F-3B (CVCS purification filters). The filters had been isolated since February 9, 2023, but were drained during the shift in preparation for the changeout. The greatest potential for creating airborne contamination is when the filter is within the drying process. During the changeout of filter 2F-3A, RP completed an air sample, but failed to analyze or count the sample, in a timely fashion, prior to the maintenance crew proceeding with the replacement of the second filter. The maintenance crew swapped out the worker and moved directly into the changeout of filter 2F-3B, as the worker from the prior filter changeout of filter 2F-3A stood by for support.
At this time, a second air sample was completed for the 2F-3B filter changeout. After the filter changeouts were completed and the work area was secured, RP proceeded to analyze and count both air samples.
During this period, two of the maintenance workers proceeded to the radiologically controlled area (RCA) exit and alarmed the personnel radiation monitors (i.e., Gamma Exit Monitor, GEM-5). The worker who changed out the 2F-3A filter was decontaminated and cleared the GEM-5 at the RCA exit. The worker who changed out the 2F-3B filter could not clear the GEM-5 and was escorted by RP to dosimetry for whole-body counting (WBC). A review of the WBC data identified the individual did have an uptake of radioactive material during the filter changeout.
The worker who changed out the 2F-3A filter initially cleared the GEM-5, but did not receive a WBC at the time of his co-worker. However, this individual alarmed a GEM-5 at the primary access point 3 days later, on April 6, 2023. At this time, the worker who changed out the 2F-3A filter received a WBC, which confirmed an uptake of radioactive material. The licensee determined the uptake was due to the filter changeout work.
The licensees review of this issue determined that the filters were dry, which increased the potential for airborne radioactivity in the work area and created unknown radiological conditions. This may have been prevented if RP would have completed an assessment of the air sample for filter changeout 2F-3A in a timely fashion, as instructed by licensee procedure.
Licensee Procedure EN-RP-131, "Air Sampling," revision 18, section 5.1.6 stated, in part,
"EVALUATE grab samples as quickly as practicable to determine the need for adjusting engineering controls. The failure to evaluate the air samples as quickly as possible resulted in not adjusting engineering controls and two confirmed uptakes of radioactive materials.
The assessment of the air samples (ANO-AS-040323-0095), dated April 3, 2023, indicated a derived air concentration (DAC) fraction of 1.54. These results indicated an airborne radioactivity area and the need for additional radiological and engineering controls to prevent unintended exposures. The additional radiological and engineering controls would have been required prior to work starting on the second filter changeout. However, the maintenance workers were allowed to continue working without additional controls being implemented, and they were not aware of the actual radiological conditions in their work area.
When the inspectors inquired about why the worker that changed out filter 2F-3A was able to pass the GEM-5 monitors at the RCA exit, the licensee stated that video footage showed both individuals monitored appropriately at the RCA exit. The licensee added that difference in body mass may have impacted the shielding of internal radionuclides, resulting in one worker being able to pass the GEM-5 monitor based on positioning. The inspectors did confirm that the satisfactory calibrations for these GEM-5 monitors were current and the alarming levels were appropriately set.
2-17
In the licensee's Condition Analysis Template, dated May 15, 2023, the licensee identified gaps in their procedural guidance relative to the verification of the filter housing configuration that attributed to this issue. In an operations procedure, there were steps that instruct workers to validate the housing configuration of the filter and evaluate and implement engineering controls prior to opening the housing when utilizing the filter transfer assembly tool. This procedure was not tied to the radiation work permit (RWP) that was used. As part of their corrective actions, the licensee plans to update the RWP with these steps and enhance procedures. Additionally, the licensee concluded the small work area in which the filters were stationed challenged RP's ability to support the work, and there should have been additional instructions to use remote monitoring to help address the risk associated with system breaches for filter changeouts.
Corrective Actions: As immediate corrective actions, the licensee performed whole body counts on the two workers and entered this issue into their corrective action program. As a follow-up, the licensee performed a dose assessment, coached all individuals involved, and made changes to their procedures in order to prevent recurrence of these failures during filter changeouts.
Corrective Action References: condition report CR-ANO-2-2023-00521
Performance Assessment:
Performance Deficiency: The licensees failure to follow procedures to assess airborne radiological conditions was a performance deficiency. This failure resulted in not implementing appropriate engineering controls and two confirmed uptakes by maintenance workers.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, this failure resulted in not implementing appropriate engineering controls and two confirmed uptakes by maintenance workers. Additionally, the performance deficiency was similar to example
- (6h) in Inspection Manual Chapter (IMC) 0612, Appendix E, "Examples of Minor Issues," in which a more than minor performance deficiency occurred when the licensee failed to establish appropriate radiological controls such that an unplanned internal exposure occurred resulting in greater than 10 mrem committed effective dose equivalent (CEDE). In this case, the two maintenance workers received 14.37 millirem CEDE and 0.4 millirem CEDE, respectively.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix C, Occupational Radiation Safety SDP. Using IMC 0609, appendix C, the inspectors determined the finding to be of very low safety significance (Green) because:
- (1) it was not a finding in ALARA Planning or Work Controls;
- (2) it was not an overexposure;
- (3) there was no substantial potential for overexposure;
- (3) it was not a shallow dose exposure or discrete radiation particle exposure; and
- (4) it was not a whole-body exposure within a very high radiation area.
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.
Specifically, the licensee failed to ensure that the workers had complete and adequate
2-18
Failure to Establish Adequate Corrective Actions Resulting in Excessive Instances of Damaged and Broken Internals of the Emergency Feedwater Pump Turbine Steam Admission Check Valves Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NOV 05000368/2023002-03 Open
[H.6] - Design Margins 71152A The inspectors identified a Unit 2 Green finding and associated Notice of Violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the failure to promptly identify and correct a condition adverse to quality. Specifically, the licensee failed to correct in a timely manner the deficient system design of the check valves admitting steam to the emergency feedwater turbine.
Description:
In 2018, the NRC issued Green, non-cited violations05000313/2018011-02 and 05000368/2018011-02, of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for both ANO units, for failure to establish an adequate corrective action program and the resulting inability to correct a deficient system design which resulted in damaged and broken internals of the check valves admitting steam to the emergency feedwater turbine.
The Unit 1, Babcock and Wilcox reactor design, safety-related function of check valve MS-271 is to open and admit steam from its steam generator to the emergency feedwater pump turbine and to close to prevent excessive loss of steam flow from the opposite steam generator such that sufficient flow of steam will pass through the sister check valve MS-272 (and vice versa). The same arrangement applies to the Unit 2, Combustion Engineering reactor design, design with check valves 2MS-39A and 2MS-39B.
Enforcement:
Violation: Technical Specifications 6.4.1.a, requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, revision 2, appendix A, February 1978. Section 7.e of appendix A of Regulatory Guide 1.33 requires procedures for radiation protection. Section 5.1.6 of Procedure EN-RP-131, "Air Sampling," revision 18, section 5.1.6, requires grab samples to be evaluated as quickly as practicable to determine the need for adjusting engineering controls.
Contrary to these requirements, on April 3, 2023, the licensee failed to follow procedure EN-RP-131 when they failed to evaluate an air sample as quickly as practicable to determine the need for adjusting engineering controls. Specifically, the licensee completed an air sample for the changeout of CVCS purification filter 2F-3A but did not evaluate the sample quickly or prior to the next filter changeout job for filter 2F-3B in the same area, which resulted in not adjusting engineering controls and confirmed uptakes of radioactive materials for two maintenance workers.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
instructions available to them, as associated with their RWP, to conduct the filter changeouts of 2F-3A and 2F-3B. The licensee also failed to ensure the workers were properly trained on the risks associated with system breaches for filter changeouts.
2-19
As part of the licensees response to the above listed NCVs, the licensee entered the deficient condition into the corrective action program and expressed a commitment to correct the condition and avoid future failures of these check valves, condition report CR-ANO-C-2018-04349. Subsequently, a new check valve design was developed under engineering change (EC) documents EC-81851 and EC-82061 and installed in each unit during refueling outages 1R28 and 2R27, work orders (WO) WO 517493, WO 517494, WO 520975, and WO 520976. Corrective actions were also implemented to replace each of the check valves every refueling outage for each unit. Additionally, the licensee implemented a modification in Unit 1 to maintain one of the steam-supply motor-operated valves (MOV)
(CV-2617) in a normally closed position to eliminate abnormal wear due to differential pressure oscillations. The Unit 1 steam admission MOVs each receive an automatic open signal on an emergency feedwater actuation signal. A similar modification was not completed for Unit 2 because the Unit 2 steam admission valves do not receive an automatic open signal on an emergency feedwater actuation signal. There have been no additional failures of Unit 1 check valves MS-271 or MS-272 since implementation of the modification in Unit 1 to keep valve CV-2617 normally closed.
On October 13, 2021, during Unit 2 refueling outage 2R28, the licensee performed an inspection of 2MS-39B and found that the check valve had failed, and its internals were missing. The licensee wrote condition report CR-ANO-2-2021-02496 to document the as found condition and developed a parts retrieval plan. The missing parts were retrieved and a new check valve of the same design as well as an acoustic monitoring device were installed.
On May 4, 2023, during Unit 2 refueling outage 2R29, the licensee performed another inspection of 2MS-39B. Again, the licensee found that the check valve had failed, and its internals were missing. The licensee wrote condition report CR-ANO-2-2023-01282 to document the as found condition and develop a parts retrieval plan. The missing parts were retrieved and a new check valve of the same design as well as an acoustic monitoring device were once again installed.
During these failures the broken internals were found to be heavily worn from excessive cycling. Check valve failures prior to the issuance of NCV 05000313/2018011-02 and NCV 05000368/2018011-02 exhibited damage also caused by excessive cycling. Operability evaluations performed for each failure always determined that the valves were operable despite their broken internals. Supporting justifications included that the check valves sufficiently passed forward steam flow as demonstrated by successfully completed surveillance tests of the turbine-driven emergency feedwater pump, loose parts evaluations that concluded any loose parts in the system would not adversely affect system operability, and engineering evaluations that concluded the as-found valve damage would not have prevented the valve from performing its closure function.
Since 2018 the licensee has not addressed the cyclic damage to the Unit 2 check valves and has not corrected the situation in a timely manner despite several refueling outages. No other compensatory measures have been established beyond the original valve replacement each cycle and the acoustic monitoring.
Corrective Actions: The licensee installed acoustic monitoring instrumentation to periodically monitor valve conditions and plans to replace the check valves again next outage.
Additionally, the licensee informed the inspectors that they would discuss operating experience with these valves with industry peers.
2-20
Corrective Action References: The licensee entered these issues into the corrective action program with condition reports CR-ANO-2-2021-02496, CR-ANO-2-2023-01282, and CR-ANO-2-2023-02140.
Performance Assessment:
Performance Deficiency: The licensees failure to correct a condition adverse to quality related to the multiple failures of safety-related emergency feedwater pump turbine steam admission check valves is a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, corrective actions taken since the NRC issued a non-cited violation in 2018 have not resolved the problem for Unit 2. The licensee continued to have failures of check valve 2MS-39B during the following two operating cycles, resulting in parts of the broken valve being found in other locations of the system, such that the overall performance of the system could not be considered as reliable as the original plant design.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. In accordance with Section A, Exhibit 2, Mitigating Systems Screening Questions, issued November 30, 2020, the finding screened as Green because it was a deficiency affecting the design or qualification of the emergency feedwater system but did not cause a loss of system operability or PRA functionality.
Cross-Cutting Aspect: H.6 - Design Margins: The organization operates and maintains equipment within design margins. Margins are carefully guarded and changed only through a systematic and rigorous process. Special attention is placed on maintaining fission product barriers, defense-in-depth, and safety-related equipment. In the case of these check valves, the organization did not maintain the equipment within their design margins and the design changes did not reflect a rigorous change process.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, "Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected."
Contrary to the above, since 2018, when the NRC issued non-cited violations05000313/2018011-02 and 05000368/2018011-02 (ML18295A382), the licensee has continued to fail to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances were promptly identified and corrected. Specifically, attempts to correct conditions adverse to quality for the Unit 2 safety-related emergency feedwater steam admission check valve, 2MS-39B, were unsuccessful because the internals of Unit 2 safety-related emergency feedwater steam admission check valve 2MS-39B were found damaged or broken during subsequent inspections in 2021 and 2023.
Enforcement Action: This violation is being cited because the licensee failed to restore compliance within a reasonable period of time after the violation was identified consistent with
2-21
section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On April 28, 2023, the inspectors presented the occupational radiation safety inspection results to Doug Pehrson, General Manager, Plant Operations, and other members of the licensee staff.
- On June 15, 2023, the inspectors presented the public radiation safety inspection results to Joseph Sullivan, Site Vice President, and other members of the licensee staff.
- On July 13, 2023, the inspectors presented the integrated inspection results to Doug Pehrson, Site Vice President, and other members of the licensee staff.
2-22
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-ANO-
1-2023-00894, 1-2023-00895, 1-2023-00896,1-2023-00897,
C-2021-01676
Drawings
M-204, Sheet 3
Emergency Feedwater
Drawings
M-204, Sheet 4
Emergency Feedwater
Drawings
M-204, Sheet 5
Emergency Feedwater Storage
Drawings
M-206, Sheet 1
Steam Generator Secondary System
133
Miscellaneous
STM 1-27
Miscellaneous
STM 1-66
Emergency Feedwater Initiation and Control
Procedures
OP-1106.006
Emergency Feedwater Pump Operation
20
Procedures
OP-1304.098
EFIC Channel A Calibration
Procedures
OP-2104.037
Alternate AC Diesel Generator Operations
Procedures
OP-3305.001
OPS System Alignment Tests
Corrective Action
Documents
CR-ANO-
2-2022-01361, 2-2022-01376, 2-2022-01454, 2-2022-01486
Engineering
Evaluations
ER-974313
Black and Green Cables Intermingled between Trays
PC-1
Miscellaneous
ANO Prefire Plan (Unit 1)
Miscellaneous
ANO Prefire Plan (Unit 2)
Calculations
CALC-95-R-0014-
Test Protocol Unit 2 Shutdown Cooling Heat Exchanger
Thermal Performance Test
Corrective Action
Documents
CR-ANO-
2-2021-03347, 2-2021-03664, C-2022-01391
Procedures
OP-2311.001
Shutdown Cooling Heat Exchanger Thermal Performance Test
Work Orders
548828, 572642, 52939676
Corrective Action
Documents
Resulting from
Inspection
CR-ANO-2-2023-
01119
NRC Inspector Observation regarding a potential issue with
2SV-8344-1 "CBHVAC H2 Purge Manifold".
04/18/2023
Corrective Action
Documents
Resulting from
Inspection
CR-ANO-C-2023-
01187
During the NRC ISI Inspection, the NRC Inspector provided an
observation regarding equipment labeling in the plant.
04/25/2023
2-23
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NDE Reports
2-BOP-MT-23-
017
Magnetic Particle Examination: MT on 2HBC-34 Weld
04/27/2023
NDE Reports
2-ISI-PT-23-001
Liquid Penetrant Examination: Integrally Welded Attachment
05/02/2023
NDE Reports
2-ISI-UT-23-001
UT Calibration/Examination: Elbow to Safe End
Circumferential Weld
04/25/2023
NDE Reports
2-ISI-UT-23-002
UT Calibration/Examination: Pipe to Elbow Circumferential
04/25/2023
NDE Reports
2-ISI-VT-23-022
Visual Examination of Pipe Hanger, Support or Restraint (VT-
3): One Way Restraint 2HBC-64-H9
04/26/2023
NDE Reports
2-ISI-VT-23-023
Visual Examination of Welds (VT-1): Integrally Welded
04/26/2023
Procedures
CEP-BAC-001
Boric Acid Corrosion Control (BACC) Program Plan
Procedures
CEP-NDE-0400
Ultrasonic Examination
Procedures
CEP-NDE-0423
Manual Ultrasonic Examination of Austenitic Piping Welds
(ASME XI)
Procedures
CEP-NDE-0497
Manual Ultrasonic Examination of Welds in Vessels (Non-App.
VIII)
Procedures
CEP-NDE-0641
Liquid Penetrant Examination (PT) for ASME Section XI
Procedures
CEP-NDE-0901
VT-1
Procedures
CEP-NDE-0902
Procedures
CEP-NDE-0903
VT-3
Procedures
CEP-NDE-0955
Visual Examination (VE) of Bare-Metal Surfaces
308
Procedures
Boric Acid Corrosion Control Program (BACCP)
Procedures
SEP-BAC-ANO-
001
Boric Acid Corrosion Control Program
Inspection and Identification of Boric Acid Leaks for
ANO-1 and ANO-2
Work Orders
00572367-01
ISI VT-1 on 73-044W Integrally Welded ATT 2HBC-64-H9
(2R29)
04/26/2023
Work Orders
00572398-01
2R29: ISI UT On 22-001A Elbow to Pipe Circ Weld 2SI-15D
04/20/2023
Work Orders
00572916-04
2R29: ISI VT-3 on 23-069 Anchor 2CCA-24-H22
Task: ISI #23-0069W: Perform at PT of the Integral
05/04/2023
Work Orders
00572925-01
2R29: ISI VT-3 ISI # 73-004 One Way Restraint 2HBC-64-H9
04/26/2023
2-24
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
00572940-01
40-008: ISI UT On Pipe to Elbow Circ Weld
04/26/2023
71111.11Q Corrective Action
Documents
CR-ANO-
2-2023-00611, 2-2023-00615
71111.11Q Miscellaneous
A1LPOPSB5B
Security Event (B5b)
2305
71111.11Q Procedures
OP-1203.048
Security Event
71111.11Q Procedures
OP-2102.004
Power Operation
71111.11Q Procedures
OP-2102.010
Plant Cooldown
71111.11Q Procedures
OP-2103.015
Reactivity Balance Calculation
71111.11Q Procedures
OP-2104.004
Shutdown Cooling System
71111.11Q Procedures
OP-2203.011
RCS Overcooling
71111.11Q Procedures
OP-2203.013
Natural Circulation Operations
Calculations
CALC-19-E-0013-
Minimum Thickness Calculation for HBD-12-36, HBD-14-18,
HBD-20-18, 2HBC-33-20, 2HBC-34-20, 2HBC-83-30, and
2HBC-88-42 Buried Pipe
Corrective Action
Documents
CR-ANO-
1-2009-00041, 1-2023-00276, 1-2023-00277, 1-2023-00301,
1-2023-00393, 1-2023-00401, 1-2023-00554, C-2019-01633,
C-2021-03142, C-2022-03087, C-2023-00972
Procedures
Microbiologically Influenced Corrosion (MIC) Monitoring
Program
Procedures
Troubleshooting and Maintenance Activities
Procedures
Limitorque Valve Operator Model SMB/B/SBD-000 Through 5
MOV and HBC Periodic Inspection
Procedures
OP-1403.038
Maintenance of Limotorque SB and SMB Actuators
Work Orders
28327, 572224, 591642, 593693, 52920155, 52965589
Corrective Action
Documents
CR-ANO-
1-2023-00304, 1-2023-00783, 1-2023-00961
Miscellaneous
Maintaining Condenser Vacuum while P-3B and P-3D are
Miscellaneous
Manually Initiated Condition Report, 6/25/2023 @ 2040
Procedures
COPD-024
Risk Assessment Guidelines
Procedures
EN-FAP-OM-029
Adverse Condition Monitoring and Contingency Planning
Procedures
OP-1107.001
Electrical System Operations
135
Procedures
OP-2107.001
Electrical System Operations
138
2-25
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
OP-2203.019
Calculations
CALC-ANO2-NE-
2-00001
ANO-2 Cycle 30 Groundrules
Corrective Action
Documents
CR-ANO-
1-2022-01995, 1-2023-00202, 1-2023-00222, 1-2023-00230,
1-2023-00280,1-2023-00668, 2-2023-01013, 2-2023-01705, 2-
23-01961
Drawings
M-2232, Sheet 1
Safety Injection System
23
Miscellaneous
Plant Data Management System: RG59B/U Coax Cable
05/05/2023
Miscellaneous
ULD-1-SYS-10
ANO-1 Service Water Systems
Procedures
Operability Determination Process
Procedures
OP-1104.029
Service Water and Auxiliary Cooling System
27
Procedures
OP-2304.113
Plant Protection System Response Time Test Channel B
Procedures
OP-3305.001
OPS System Alignment Tests
Procedures
OP-6030.109
Installation of Electrical Cable & Wire
Work Orders
455328, 571414, 594717, 595779, 52983646
Calculations
CALC-91-E-0016-
Valves CV-3811 & CV-3821
Corrective Action
Documents
CR-ANO-
1-2020-00762, 1-2023-00275, 1-2023-00277, 1-2023-00554,
1-2023-00960, 2-2023-00327, 2-2023-00562, 2-2023-00575,
2-2023-00626, C-2023-00947, C-2023-01019
Drawings
13-SW-119,
Sheet 1
Large Pipe Isometric Service Water Supply
Drawings
M-210, Sheet 1
155
Engineering
Changes
Evaluate Temporary Modification to Provide Alternate Source
of Power to Spent Fuel Cooling Pump 2P-40A or 2P-40B
Engineering
Changes
Evaluation of a Temporary Spent Fuel Pool (SFP) Cooling
System
Engineering
Changes
Evaluate and Provide Guidance for Providing Temp Power to
Both U2 SFP Cooling Pumps 2P-40A and 2P-40B
Engineering
Changes
U1 Service Water Butterfly Valve Replacements (Loop 2)
Engineering
Changes
CV-3811 Thread Engagement Discussion
Engineering
ER-ANO-2003-
Engineering Evaluation for ANO-2 SU Channel T-Alt
2-26
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Evaluations
0583-001
Procedures
Limitorque Valve Operator Model SMB/B/SBD-000 Through 5
MOV and HBC Periodic Inspection
Procedures
Maintenance Standard for Torque Applications
Procedures
OP-1403.038
Maintenance of Limotorque SB and SMB Actuators
Procedures
OP-2104.006
Fuel Pool Systems
Procedures
OP-2203.002
Spent Fuel Pool Emergencies
Procedures
OP-2303.145
Startup Channels 1 & 2 Test
Procedures
OP-2311.001
Shutdown Cooling Heat Exchanger Performance Test
Procedures
OP-2403.270
Alternate Startup Channel Using Excore Detector
Work Orders
539568, 568997, 574775
Calculations
CALC-90-R-2006-
Fatigue Monitoring Program for AP&L at ANO-2
Calculations
CALC-ANO2-ME-
1500009
Review of the Fatigue Monitoring Program for License
Renewal Implementation
Corrective Action
Documents
CR-ANO-
2-2023-00137, 2-2023-00150, 2-2023-00615, 2-2023-00616,
2-2023-01569, 2-2023-01571, 2-2023-01598, 2-2023-01619,
2-2023-01647, 2-2023-01705, 2-2023-01760
Miscellaneous
PWR Startup Critical Predictions and Evaluation Process
Procedures
COLR-U2
Core Operating Limits Report for Cycle 30
Procedures
Fatigue Management Program
Procedures
OP-1010.002
Unit Two Transient Cycle Logging and Reporting
Procedures
OP-1015.048
Shutdown Operations Protection Plan
and 34
Procedures
OP-2102.001
Plant Pre-Heatup and Pre-Critical Checklist
Procedures
OP-2102.002
Plant Heatup
Procedures
OP-2102.004
Power Operation
Procedures
OP-2102.010
Plant Cooldown
Procedures
OP-2102.015
Filling and Draining the Refueling Canal
Procedures
OP-2102.016
Reactor Startup
Procedures
OP-2103.006
Reactor Coolant Pump Operations
Procedures
OP-2103.011
Draining the Reactor Coolant System
Procedures
OP-2106.009
Turbine Generator Operations
Procedures
OP-2203.025
RCP Emergencies
2-27
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
OP-2302.022
Initial Criticality Following Refueling
Corrective Action
Documents
CR-ANO-
1-2020-01707, 1-2023-00276, 1-2023-00277, 1-2023-00393,
1-2023-00401, 2-2020-00661, 2-2022-00495, 2-2023-00032,
2-2023-00378, 2-2023-00525, 2-2023-00577, 2-2023-01598,
2-2023-01647, 2-2023-01702, 2-2023-01703, C-2021-02976,
C-2021-02985, C-2023-00628, C-2023-01232, C-2023-01280,
C-2023-01337,
Drawings
M-2230, Sheet 1
Drawings
M-2232, Sheet 1
Safety Injection System
23
Miscellaneous
ULD-0-TOP-15
Procedures
CFSG-005
Initial Assessment and FLEX Equipment Staging
Procedures
Limitorque Valve Operator Model SMB/SB/SBD-000 through 5
MOV an HBC Periodic Inspection
Procedures
OP-1104.032
Fire Protection Systems
Procedures
OP-2104.005
Procedures
OP-2104.039
HPSI System Operation
Procedures
OP-2106.009
Turbine Generator Operations
Procedures
OP-2304.039
Unit 2 Plant Protection System Channel C Test
Procedures
OP-2304.133
Unit 2 High Range Containment Radiation Monitor Calibration
Procedures
OP-2306.006
Unit 2 Main Steam Safety Valve Test
Procedures
OP-2307.009
Pressurizer Proportional Heater Checkout
Procedures
OP-2402.044
Disassembly, Inspection, & Reassembly of 2SI-26 A&B, 27
A&B, 28 A&B
Work Orders
573697, 593904, 594187, 595692, 595693, 52956635,
2965589, 52984752, 52984753, 52984754, 52984755,
2984756, 53021361, 53021367, 53026640, 53027917,
53033688,
ALARA Plans
23-2904
Unit 2 Radiological Diving Operations for Repairs to Refuel
Equipment
04/28/2023
Corrective Action
Documents
CR-ANO-
1-2022-02079, 1-2022-02084, 1-2022-02196, 1-2022-02254,
1-2022-02310, 1-2022-02445, 1-2022-02447, 1-2022-02505,
1-2022-03062, 2-2023-00521, 2-2023-00866, C-2022-01820,
C-2022-03025, C-2022-03090, C-2022-03552, C-2023-00261,
C-2023-00362, C-2023-00766, C-2023-00956, C-2023-01022
2-28
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Resulting from
Inspection
CR-ANO-
1-2023-00690, 2-2023-01057, 2-2023-01058
Procedures
Radiation Worker Expectations
Procedures
Access Control for Radiologically Controlled Areas
Procedures
Radiological Control
Procedures
Radiological Work Permits
Procedures
Radiation Protection Posting
Procedures
ALARA Program
Procedures
Radioactive Material Control
Procedures
Air Sampling
Radiation Surveys
ANO-21-10-
00450
BWST Area 354' Elevation
10/07/2021
Radiation Surveys
ANO-21-10-
00490
BWST Area 354'Elevation - Breach inside 2T3 RWT
10/08/2021
Radiation Surveys
ANO-21-12-
00180
Unit 2 Spent Fuel Pool Items
2/13/2021
Radiation Surveys
ANO-22-11-
00819
Unit 1 Spent Fuel Pool Items
11/30/2022
Radiation Surveys
ANO-23-04-
00039
Unit 2 Auxiliary Building 335' Elevation - follow up survey after
2-F3 A/B filter change out
04/04/2023
Radiation Surveys
ANO-23-04-
00611
Air Sample: Unit 2 Reactor Building 401' Elevation - under
head dose rate survey
04/19/2023
Radiation Surveys
ANO-23-04-
00953
Air Sample: Unit 2 Reactor Building 405' Elevation - under
head entry
04/24/2023
Radiation Surveys
ANO-AS-042323-
23
Air Sample: Unit 2 Reactor Building 404' Elevation - ICI
inspection
04/23/2023
Radiation Surveys
ANO-AS-042323-
24
Air Sample: Unit 2 Reactor Building 404' Elevation - under
reactor head tool changeout
04/23/2023
Radiation Surveys
ANO-AS-042323-
252
Air Sample: Unit 2 Reactor Building 404' Elevation - ROSA
04/23/2023
Radiation Surveys
ANO-AS-042323-
265
Air Sample: Unit 2 Reactor Building 404' Elevation - RX head
stand inspect ROSA
04/23/2023
2-29
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Radiation Surveys
ANO-AS-042323-
267
Air Sample: Unit 2 Reactor Building 404' Elevation - RX head
tool cleaning
04/23/2023
Radiation Surveys
ANO-AS-042523-
0305
Air Sample: Unit 2 Reactor Building 404' Elevation - under
head inspection
04/25/2023
Radiation Surveys
ANO-AS-102322-
0359
Air Sample: Unit 1 Reactor Building 335' Elevation - CF-1B
reassembly
10/22/2022
Radiation Surveys
ANO-AS-102822-
0392
Air Sample: Unit 1 Reactor Building 426 Elevation - vacuum
change out
10/27/2022
Radiation Surveys
ANO-AS-110622-
0458
Air Sample: Unit 1 Reactor Building 404' Elevation - Incore
tank
11/06/2022
Radiation Surveys
ANO-AS-111522-
0493
Air Sample: Unit 1 Reactor Building 404' elevation - not
used/cross contaminated
11/15/2022
Radiation Surveys
ANO-AS-122922-
0600
Air Sample: Unit 1 Reactor Building 386' Elevation - D-RCP
Startup
2/29/2022
Radiation Surveys
RWP 2022-1430
Task 3
Lapel Air Sample - Alpha Level 2 Area
11/06/2022
Radiation Surveys
RWP 2022-1433
Task 5
Lapel Air Sample - Alpha Level 2 Area
10/29/2022
Radiation Surveys
RWP 2022-1433,
Task 2
Lapel Air Sample - Alpha Level 2 Area
11/06/2022
Radiation Surveys
RWP 2022-1900
Task 5
Lapel Air Sample - Alpha Level 2 Area
2/22/2022
Radiation Work
Permits (RWPs)
22-1420
1R30 Scaffold Activities
Radiation Work
Permits (RWPs)
22-1430
1R30 Reactor Disassembly, Re-assembly and Support
Activities
Radiation Work
Permits (RWPs)
22-1433
1R30 Remove and Replace (4) In-core detectors
Radiation Work
Permits (RWPs)
22-1500
1R30 P-32B - RCP Motor and Rotating Assembly
Replacement
Radiation Work
Permits (RWPs)
22-1502
1R30 Pressurizer Heater Bundle/Cable Replacement
Radiation Work
Permits (RWPs)
22-1900
1R30 Emergent Maintenance
2-30
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Radiation Work
Permits (RWPs)
23-2455
2SI-3B Disassemble, Inspect, and Repair
Radiation Work
Permits (RWPs)
23-2465
2R29 - RCP Seal Replacement for 2P-32A, 2P-32B, and 2P-
2D
Radiation Work
Permits (RWPs)
23-2471
2R29 Inspections on Unit 2 Reactor Head
Radiation Work
Permits (RWPs)
23-2474
2R29 RWT Tank Maintenance and Inspections
Self-Assessments
LO-ALO-2022-
00085
Focused Self-Assessment: Radiation Inspection -
Radiological Hazards and Exposure Controls, Occupational
Dose Assessment, and Performance Indicator Verification
IP-71124.01, IP-71124.04, IP-71151
2/19/2022
Corrective Action
Documents
CR-ANO-
C-2021-02306, C-2021-02614, C-2021-02656, C-2021-02659,
C-2021-02732, C-2021-03209, C-2021-03268, 2-2021-02120,
C-2022-00715, C-2022-00716, C-2022-01167, 1-2022-01972,
1-2022-03043, 2-2023-00521, C-2023-00540
Corrective Action
Documents
Resulting from
Inspection
CR-HQN-
23-00575
Miscellaneous
21 Self-Reading Dosimeter (SRD) versus Dosimeter of
Legal Record (DLR) Discrepancies
21
Miscellaneous
22 Self-Reading Dosimeter (SRD) versus Dosimeter of
Legal Record (DLR) Discrepancies
22
Miscellaneous
NVLAP Certificate of Accreditation to ISO/IEC 17025:2017 for
Landauer, Inc., 1/1/2023 - 12/31/2023
01/01/2023
Miscellaneous
Station 5-Year Exposure Reduction Plant Template: Arkansas
Nuclear One 5-Year Exposure Reduction Plan 2023-2027
2/12/2022
Miscellaneous
2015 ANO Neutron Radiation Assessment Report
04/11/2016
Miscellaneous
TEDE-ALARA Evaluation for RWP 2023-2471, Task 3, "Under
Head - All entries except CEDM Nozzle 71"
11/16/2022
Miscellaneous
21 - 2023 List of Multipack TLD Assignment: EDEX work
activities and dose assigned
03/06/2023
Miscellaneous
ANO-RPT-21-002
Site Radiological Characterization and Assessment
2/27/2021
2-31
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
PCE 2021-018
Personnel Contamination Event - Hair
11/24/2021
Miscellaneous
PCE 2022-009
Personnel Contamination Event - Facial
10/21/2022
Miscellaneous
PCE 2022-011
Personnel Contamination Event - Facial
2/24/2022
Miscellaneous
Sample 22-07076
CFR Part 61 Waste Stream Sample Screening and
Evaluation: 2022 Dry Active Waste
01/11/2023
Procedures
Alpha Monitoring
Procedures
Job Coverage
Procedures
EN-RP-141-02
Discrete Radioactive Particle Control
Procedures
Dosimetry Administration
Procedures
Personnel Monitoring
Procedures
Dose Assessment
Procedures
Special Monitoring Requirements
Procedures
Dosimeter of Legal Record Quality Assurance
Procedures
Whole Body Counting / In-Vitro Bioassay
Procedures
Scaling Factors
Radiation Surveys
ANO-21-09-
00317
PS5-01 Location CSB 1st Floor
09/21/2021
Radiation Surveys
ANO-21-12-
00172
Radwaste-05 Sealand Storage
2/13/2021
Radiation Surveys
ANO-22-07-
00087
PS5-01 Location CSB 1st Floor
07/07/2022
Radiation Surveys
ANO-23-04-
00039
Unit 2 AUX 335 EL 2F3 A/B Room #20327
04/04/2023
Radiation Surveys
ANO-AS-040323-
0094
Air Sample: Filter Changeout for 2F-3B Filter
04/03/2023
Radiation Surveys
ANO-AS-040323-
0095
Air Sample: Filter Changeout for 2F-3A Filter
04/03/2023
Radiation Work
Permits (RWPs)
21-2430
2R28 Reactor Disassembly / Reassembly
Radiation Work
Permits (RWPs)
21-2471
2R28 Inspections and Laser Peening on Unit 2 Reactor Head
Radiation Work
22-1061
Unit 1 Reactor Building Entry At Power
2-32
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Permits (RWPs)
Radiation Work
Permits (RWPs)
23-2052
Unit 2 Change Spent Plant Process Filters
Radiation Work
Permits (RWPs)
23-2471
2R29 Inspections on Unit 2 Reactor Head
Self-Assessments
LO-ALO-2022-
00085
Radiation Inspection - Radiological Hazards and Exposure
Controls, Occupational Dose Assessment, and Performance
Indicator Verification IP 71124.01, IP 71124.04, IP 71151
2/19/2022
Corrective Action
Documents
CR-ANO-
1-2023-00537
Corrective Action
Documents
Resulting from
Inspection
CR-ANO-
2-2023-01054
Corrective Action
Documents
CR-ANO-
1-2021-00341, 1-2021-03102, 1-2022-01118, 1-2022-01131,
1-2022-03171, 1-2023-00155, 1-2023-00160, 1-2023-00221,
1-2023-00282, 2-2020-01432, 2-2022-01916, 2-2022-01954,
2-2022-01991, 2-2023-01937, C-2022-02564, C-2022-03107,
C-2023-00222, C-2023-00541
Corrective Action
Documents
Resulting from
Inspection
CR-ANO-
C-2023-01679
Miscellaneous
0CAN042102
Radioactive Effluent Release Report for 2020
04/21/2021
Miscellaneous
0CAN042202
Radioactive Effluent Release Report for 2021
04/14/2022
Miscellaneous
0CAN042301
Radioactive Effluent Release Report for 2022
04/14/2023
Miscellaneous
1Q2022
Results of Radiochemistry Cross Check Program - Entergy,
Arkansas Nuclear One
05/18/2022
Miscellaneous
21
Land Use Census
08/12/2021
Miscellaneous
22
CFR Part 61 waste stream analysis - dry active waste
01/11/2023
Miscellaneous
2Q2022
Results of Radiochemistry Cross Check Program - Entergy,
Arkansas Nuclear One
08/30/2022
Procedures
1607.010
Sampling of Unit Vents
Procedures
1618.011
Sampling the Unit 1 Neutralizing Tank
2-33
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
20.417
In-place Testing of the Unit 1 Penetration Room Filtration
Systems
Procedures
Annual Radioactive Effluent Release Report
Procedures
HES-06
Ventilation/Filtration Testing Program
Procedures
Offsite Dose Calculation Manual
Radiation Surveys
Gaseous Release
Permits -
1GR20YY-ZZZZ
20-0061, 20-0092, 21-0018, 21-0026, 21-0029, 22-0012, 22-
0049, 22-0080, 22-0088, 23-0002
Radiation Surveys
Gaseous Release
Permits -
2GR20YY-ZZZZ
20-0065, 20-0072, 20-0094, 20-0107, 21-0014, 21-0034, 21-
0068, 21-0097, 22-0017, 22-0028, 22-0063, 23-0023, 23-0036
Radiation Surveys
Liquid Release
Permits -
1LR20YY-ZZZZ
20-0042, 20-0050, 21-0018, 21-0029, 21-0052, 21-0065, 21-
0089, 22-0015, 22-0028, 22-0041, 22-0054, 22-0073, 23-
0001, 23-0016
Radiation Surveys
Liquid Release
Permits -
2LR20YY-ZZZZ
20-0025, 20-0044, 21-0009, 21-0020, 21-0028, 22-0005, 22-
0008, 22-0009, 23-0002, 23-0017
Self-Assessments
LO-ALO-2022-
00075
Pre-NRC Inspection Assessment:
Radioactive Gaseous and Liquid Effluent Treatment,
Radiological Environmental
Monitoring Program
2/01/2023
Self-Assessments
NAQA-20-0029
To evaluate the effectiveness of the Environmental Dosimetry
Company quality assurance program as implemented by their
quality assurance manual
08/19/2020
Self-Assessments
NQ-2021-016
QA Audit Report QA-2/6-2021-ANO-01, 2021 QA Audit of
Chemistry,
Effluents & Environmental Monitoring Programs at Arkansas
Nuclear One (ANO)
09/16/2021
Self-Assessments
WT-WTHQN-
21-
00564/NUPIC
To evaluate the adequacy and implementation of the Teledyne
Brown Engineering -Environment Services quality program for
the product/service
03/08/2022
Work Orders
00572329 01
Repair Sagging Tubing Cause Water Intrusion on RX-9830
11/28/2022
Work Orders
00583738 01
Replace VFC-1 charcoal filters
2/13/2023
Work Orders
293635 01
Perform the Qtrly Channel Test of Sping 3, RX-9830
2/20/2021
2-34
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
2956781 01
Perform 18m test of VEF-38A (pent. room ventilation)
20.417, VEF-38A - mech obtain charcoal sample
03/28/2022
Work Orders
2957597 01
Perform 18m test of VEF-38-B (pent room vent)
OP-5120.417, VEF-38B - mech to obtain charcoal sample
05/13/2022
Work Orders
2972191
Charcoal filter testing results
07/25/2022
Work Orders
2972191 01
20.413, 18m VEF-14 (fuel handling area) test
VEF-14 A/B - mech to obtain charcoal sample
07/13/2022
Calibration
Records
Discharge canal composite sampler calibration
05/01/2023
Calibration
Records
AS001
Air Station 1 Rotameter Calibration
04/28/2023
Corrective Action
Documents
CR-ANO-
1-2021-03220, 2-2022-00471, 2-2023-00494, C-2021-01467,
C-2021-01612, C-2021-01887, C-2021-02292, C-2021-02354
Corrective Action
Documents
Resulting from
Inspection
CR-ANO-
1-2023-00854, C-2023-01665, C-2023-01676, C-2023-01686,
C-2023-01687, C-2023-02950
Miscellaneous
Annual Quality Assurance Status Report - January -
December 2022
03/24/2023
Miscellaneous
First Quarter of 2023 Environmental Dosimetry Data
05/24/2023
Miscellaneous
Quality control chart for chemistry count room gamma detector
- 2 for 05/01/2023 to 06/13/2023
Miscellaneous
Quality control chart for chemistry count room gamma detector
- 3 for 05/01/2023 to 06/13/2023
Miscellaneous
Liquid scintillation counting for gross beta and Tritium
measurements for Tri-Carb 4910 liquid scintillation counter #1
04/19/2023
Procedures
Laboratory Analytical Quality Control
Procedures
Land Use Census
Procedures
EN-CY-130-01
Radiological Environmental Monitoring Program (REMP)
Arkansas Nuclear One
Procedures
SOP 100
Standard Operating Procedures for Groundwater Monitoring
and Investigations
Work Orders
Semi-annual meteorological monitoring calibration
2/02/2022
Work Orders
Met tower elevator drive cable replacement
06/28/2021
2-35
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
Met tower investigation and repair inidcation
10/15/2021
Work Orders
Met tower anchor inspection
07/27/2021
Work Orders
Met tower guyed wire inspection
07/14/2021
Work Orders
Semi-annual meteorological monitoring calibration
06/02/2022
71151
Miscellaneous
ANO-1 and ANO-2 NRC Performance Indicator
Technique/Data Sheets - Mitigating Systems
Q3-2022
71151
Miscellaneous
ANO-1 and ANO-2 NRC Performance Indicator
Technique/Data Sheets - Mitigating Systems
Q4-2022
71151
Miscellaneous
ANO-1 and ANO-2 NRC Performance Indicator
Technique/Data Sheets - Mitigating Systems
Q1-2023
71151
Miscellaneous
ANO-1 and ANO-2 NRC Performance Indicator
Technique/Data Sheets - Barrier Integrity
Q2-2022
71151
Miscellaneous
ANO-1 and ANO-2 NRC Performance Indicator
Technique/Data Sheets - Barrier Integrity
Q3-2022
71151
Miscellaneous
ANO-1 and ANO-2 NRC Performance Indicator
Technique/Data Sheets - Barrier Integrity
Q4-2022
71151
Miscellaneous
ANO-1 and ANO-2 NRC Performance Indicator
Technique/Data Sheets - Barrier Integrity
Q1-2023
71151
Miscellaneous
ANO-1 and ANO-2 NRC Performance Indicator
Technique/Data Sheets - Mitigating Systems
Q2-2022
71151
Miscellaneous
EN-LI-114, Att. 1
NRC Performance Indicator Technique / Data Sheet: 4th
Quarter of 2022 for RETS/ODCM Radiological Effluent
Occurrence
01/04/2023
71151
Miscellaneous
OR01
RCA entries >100 millirem
71151
Procedures
Regulatory Performance Indicator Process
19, 20
Corrective Action
Documents
1-1016-00327, 1-2018-03832, 1-2023-00214, 1-2023-00275,
1-2023-00276, 1-2023-00277, 1-2023-00393, 1-2023-00401,
1-2023-00554, 1-2023-00962, 2-2021-02496, 2-2023-00108,
2-2023-00387, 2-2023-00540, 2-2023-01057, 2-2023-01282,
2-2023-02140, C-2018-03178, C-2022-00147, C-2023-00912,
C-2023-00972, C-2023-01003, C-2023-01260, C-2023-03008
Engineering
Changes
MS-271 and MS-272 EFW Crosstie Replacement
Engineering
2-36
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Changes
Miscellaneous
Fire Hazards Analysis
Miscellaneous
ANO Prefire Plan (Unit 1)
Procedures
General Industrial Safety Requirements
Procedures
Fall Protection
Procedures
Control Of Scaffolding
Procedures
Limitorque Valve Operator Model SMB/SB/SBD-000 through 5
MOV and HBC Periodic Inspection Procedures
Procedures
Motor Operated Valve Diagnostics
Work Orders
WO 517493, 517494, 520975, 593693, 52932138, 52996885
Corrective Action
Documents 71153
CR-ANO-
1-2023-00252, 1-2023-00290, 1-2023-00325, 1-2023-00399,
1-2023-00611, 1-2023-00650,1-2023-00837, 2-2023-01929, 2-
23-01938, 2-2023-01939
Miscellaneous
Unit 2 Narrative Log
06/14/2023
Miscellaneous
Unit 2 Narrative Log
06/15/2023
Procedures
OP-1412.022
Protect, Relay Test & Insp of RCS Pump UndrwrRelay GE Mdl
CFW11E
Procedures
OP-2203.027
Loss of Main Feedwater Pump
19