ML18120A037

Errata Arkansas Nuclear One - NRC Integrated Inspection Report 05000313/2018001 and 05000368/2018001 and Independent Spent Fuel Storage Installation Inspection Report 07200013/2018001

ML18120A037
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/30/2018
From:	O'Keefe N NRC/RGN-IV/DRP/RPB-E
To:	Richard Anderson Entergy Operations
O'Keefe C
References
ML18115A417 IR 2017001, IR 2018001
Download: ML18120A037 (44)

See also: IR 05000313/2018001

Text

April 30, 2018

Mr. Richard L. Anderson

Site Vice President

Entergy Operations, Inc.

Arkansas Nuclear One

1448 S.R. 333

Russellville, AR 72802

SUBJECT: ERRATA FOR ARKANSAS NUCLEAR ONE - NRC INTEGRATED

INSPECTION REPORT 05000313/2018001 AND 05000368/2018001 AND

INDEPENDENT SPENT FUEL STORAGE INSTALLATION INSPECTION

REPORT 07200013/2018001

Dear Mr. Anderson:

It was identified that the inspection report sent to you dated April 25, 2018 (NRCs Agencywide

Documents Access and Management System (ADAMS) Accession No. ML18115A417)

improperly listed the Independent Spent Fuel Storage Installation Inspection Report number as

07200013/2018001 in the subject lines, enclosure block, and page one of the enclosure of the

original letter. The correct inspection report number should read 07200013/2017001 in all

areas. Please note none of the content of the inspection report has changed.

This letter, its enclosure, and your response (if any) 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for

Withholding.

Sincerely,

/RA/

Neil OKeefe, Chief

Branch E

Division of Reactor Projects

Docket Nos. 50-313 and 50-368

License Nos. DPR-51 and NPF-6

Enclosure:

Inspection Report 05000313/2018001 and

05000368/2018001 and 07200013/2017001

w/ Attachments

April 30, 2018

Mr. Richard L. Anderson

Site Vice President

Entergy Operations, Inc.

Arkansas Nuclear One

1448 S.R. 333

Russellville, AR 72802

SUBJECT: ARKANSAS NUCLEAR ONE - NRC INTEGRATED INSPECTION REPORT

05000313/2018001 AND 05000368/2018001 AND INDEPENDENT SPENT

FUEL STORAGE INSTALLATION INSPECTION REPORT 07200013/2017001

Dear Mr. Anderson:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at your Arkansas Nuclear One facility, Units 1 and 2. On April 5, 2018, the NRC inspectors

discussed the results of this inspection with Mr. John Kirkpatrick, General Manager of Plant

Operations, and other members of your staff. On April 18, 2018, the NRC inspectors exited to

modify the characterization of one finding with Ms. Stephanie Pyle, Regulatory Assurance

Manager. The results of this inspection are documented in the enclosed report.

NRC inspectors documented two findings of very low safety significance (Green) in this report.

Both of these findings involved a violation of NRC requirements. Additionally, NRC inspectors

documented a licensee-identified violation, which was determined to be of very low safety

significance (Green), in this report. The NRC is treating these violations as non-cited violations

(NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or significance of the NCVs, 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 the Arkansas Nuclear One.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a

regulatory requirement 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 the Arkansas Nuclear

One.

Enclosure

R. Anderson 2

This letter, its enclosure, and your response (if any) 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for

Withholding.

Sincerely,

/RA/

Neil OKeefe, Chief

Branch E

Division of Reactor Projects

Docket Nos. 50-313 and 50-368

License Nos. DPR-51 and NPF-6

Enclosure:

Inspection Report 05000313/2018001 and

05000368/2018001 and 07200013/2017001

w/ Attachments:

1. Documents Reviewed

2. Occupational Radiation Safety Inspection

Request for Information

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Numbers: 05000313; 05000368; and 07200013

License Numbers: DPR-51; NPF-6

Report Numbers: 05000313/2018001; 05000368/2018001; and 07200013/2017001

Licensee: Entergy Operations, Inc.

Facility: Arkansas Nuclear One, Units 1 and 2, and Independent Spent Fuel

Storage Installation

Location: Junction of Highway 64 West and Highway 333 South

Russellville, Arkansas

Inspection Dates: January 1, 2018 to March 31, 2018

Inspectors: C. Henderson, Senior Resident Inspector

P. Smagacz, Acting Senior Resident Inspector

T. Sullivan, Resident Inspector

M. Tobin, Resident Inspector

L. Brookhart, Senior Inspector

N. Greene, Ph.D., Senior Health Physicist

J. ODonnell, CHP, Health Physicist

Approved By: N. OKeefe, Branch Chief

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees

performance by conducting an integrated inspection at Arkansas Nuclear One, Units 1 and 2, 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. NRC-identified and

self-revealed findings and violations, and additional items are summarized in the tables below.

A licensee-identified, non-cited violation is documented in report Section 71124.01.

List of Findings and Violations

Failure to Establish Adequate Criteria for Flood Seal Testing

Cornerstone Significance Cross-cutting Inspection

Aspect Procedure

Mitigating Green Finding [H.12] - Avoid 71111.01 -

Systems NCV 05000313/2018001-01 and Complacency External

05000368/2018001-01 Flooding

Closed

The inspectors identified a Green finding and associated non-cited violation of Unit 1 Technical

Specification 5.4.1.a and Unit 2 Technical Specification 6.4.1.a for the licensees failure to

establish the criteria for ensuring the necessary conditions existed for a successful test of

hatch flood seals. Specifically, Procedure OP 1402.240, Inspection of Watertight Hatches,

Revision 1, did not contain adequate guidance to ensure that the auxiliary building was at a

lower pressure than the turbine building such that puffing smoke on the turbine building side

would allow a seal leak to be detectable.

Failure to Preplan and Perform Service Water Pre-Screen Maintenance

Cornerstone Significance Cross-cutting Inspection

Aspect Procedure

Mitigating Green Finding [H.12] - Avoid 71152 -

Systems NCV 05000368/2018001-02 Complacency Problem

Closed Identification

and

Resolution

The inspectors reviewed a self-revealed, non-cited violation and associated finding of

Arkansas Nuclear One, Unit 2, Technical Specification 6.4.1.a, for the licensees failure to

properly preplan maintenance that can affect the performance of safety-related equipment.

Specifically, the licensee failed to properly preplan pre-screen cleaning maintenance, causing

the train B service water system to become inoperable.

Additional Tracking Items

Type Issue number Title Inspection Status

Procedure

URI 7200013/2012001-02 Validation of the ANO data 60855.1 Closed

collected during the thermal

validation test and used in

the Holtec analysis

2

Type Issue number Title Inspection Status

Procedure

URI 7200013/2012001-03 Applicability of the ANO 60855.1 Closed

thermal validation test results

to other HI-STORM 100

overpack configurations

LER 05000313/2016-002-00 Tornado Missile Vulnerability 71153 Closed

Resulting in Condition

Prohibited By Technical

Specifications

3

PLANT STATUS

Unit 1 began the inspection period at full power. On March 24, 2018, the unit was shut down to

begin Refueling Outage 1R27.

Unit 2 began the inspection period at full power. On January 14, 2018, the unit reduced power

to 83 percent to perform planned condenser water box cleaning. The unit was returned to rated

thermal power on January 19, 2018.

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 plant status activities described in

IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem

Identification and Resolution. 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.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather (1 Sample)

The inspectors evaluated readiness for seasonal extreme weather conditions prior to the

onset of seasonal cold temperatures.

• Unit 1 and Unit 2 diesel fuel oil vault on January 30, 2018

• Unit 2 emergency diesel generator 2 on January 30, 2018

• Alternate ac diesel generator on January 30, 2018

• Unit 1 and Unit 2 emergency cooling pond on January 30, 2018

External Flooding (1 Sample)

The inspectors evaluated readiness to cope with external flooding on March 16, 2018.

A finding associated with this inspection is documented in the Inspection Results section

below.

4

71111.04 - Equipment Alignment

Partial Walkdown (4 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) Unit 2 train A emergency feedwater system during planned maintenance of train B

emergency feedwater system on February 7, 2018

(2) Unit 2 swing service water pump B aligned to the emergency cooling pond during intake

structure pre-screen cleaning and maintenance on February 22, 2018

(3) Unit 2 emergency diesel generator 2 ventilation system on March 2, 2018

(4) Unit 1 temporary reactor vessel level identification system on March 28, 2018

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the Unit 2

service water system on March 14, 2018.

71111.05 - Fire Protection Annual/Quarterly

Quarterly Inspection (4 Samples)

The inspectors evaluated fire protection program implementation in the following selected

areas:

(1) Unit 2 auxiliary building corridor 2109 temporary safety-related battery heating, Fire

Area MM, Fire Zone 2103-V, on January 30, 2018

(2) Unit 1 cable spreading room, Fire Area G, Fire Zone 97-R, on January 31, 2018

(3) Unit 2 upper south piping penetration room, Fire Area EE-L , Fire Zone 2084-DD, on

February 8, 2018

(4) Unit 2 lower south piping penetration room, Fire Area EE-L, Fire Zone 2055-JJ, on

February 8, 2018

Annual Inspection (1 Sample)

The inspectors evaluated fire brigade performance in the Unit 1 control room for a simulated

fire emergency feedwater pump room and the Unit 2 turbine deck for a simulated fire in the

turbine generator on January 4, 2018, and March 09, 2018.

5

71111.06 - Flood Protection Measures

Internal Flooding (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the Unit 2 emergency

feedwater room floor drain system on March 16, 2018.

Cables (1 Sample)

The inspectors evaluated cable submergence protection in Manhole 8 on March 1, 2018.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (2 Samples)

(1) The inspectors observed and evaluated Unit 1 simulator training for operating crews on

reactor shutdown and decay heat removal on February 22, 2018.

(2) The inspectors observed and evaluated Unit 2 simulator training for operating crews on

reactor coolant pump motor fire and security related events on February 22, 2018.

Operator Performance (2 Samples)

(1) The inspectors observed and evaluated Unit 2 return to near 100 percent power following

condenser cleaning on January 18, 2018.

(2) The inspectors observed and evaluated Unit 1 reactor shutdown for commencing Refuel

Outage 1R27 on March 23, 2018.

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness (3 Samples)

The inspectors evaluated the effectiveness of routine maintenance activities associated

with the following equipment and/or safety significant functions:

(1) Unit 1 rod control system on January 31, 2018

(2) Unit 2 service water system on March 6, 2018

(3) Internal and external flood seals on March 16, 2018

Quality Control (1 Sample)

The inspectors evaluated maintenance and quality control activities associated with the

following equipment performance issues:

(1) Unit 2 control element assembly system on January 31, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control (6 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent

work activities:

(1) Unit 2 planned work activities for control element assembly 5 repair on January 5, 2018

6

(2) Unit 2 emergent work activities for emergency diesel generator 2 on January 10, 2018

(3) Unit 2 emergent work activities for service water pump A and C strainer cleaning

following high differential pressure alarm during pre-screen cleaning on

January 19, 2018

(4) Unit 1 and Unit 2 planned work activities for startup transformer 1 and 3 outage for

autotransformer insulator repair on February 2, 2018

(5) Unit 2 planned work activities for service water bay pre-screen cleaning and

maintenance on February 22, 2018

(6) Unit 2 service water pre-screen cleaning on February 22, 2018

71111.15 - Operability Determinations and Functionality Assessments (6 Samples)

The inspectors evaluated the following operability determinations and functionality

assessments:

(1) Unit 1 operability determination for auxiliary building tornado missile protection wall

missing rebar on January 18, 2018

(2) Unit 1 operability determination for emergency feedwater control valve, CV-2646, stroke

time outside operability limits on January 22, 2018

(3) Unit 2 operability determination for emergency diesel generator 2 relay failure and

automatic start function for containment coolers on January 24, 2018

(4) Unit 1 and Unit 2 operability determination for emergency cooling pond during cold

weather impact of safety-related pumps operating oil temperature on January 31, 2018

(5) Unit 1 and Unit 2 operability determination for 500 kV offsite circuit autotransformer

damaged insulator on February 9, 2018

(6) Unit 2 functional determination emergency feedwater system room floor drain system on

March 16, 2018

71111.18 - Plant Modifications (2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Unit 2 temporary modification for lifting leads for control element assembly 4 for

degraded upper gripper coils on January 5, 2018

(2) Unit 2 temporary battery room heating on January 30, 2018

71111.19 - Post Maintenance Testing (4 Samples)

The inspectors evaluated the following post maintenance tests:

(1) Unit 2 replacement of service water pump A and C strainers on January 20, 2018

7

(2) Unit 1 auxiliary building hatch HTC-492 smoke testing following resin transfer on

February 14, 2018

(3) Unit 2 motor driven emergency feedwater pump flow transmitter calibration due to the

transmitter reading low out of range on February 20, 2018

(4) Unit 1 temporary reactor vessel level indication due valve, RC-1, repair on

March 28, 2018

71111.20 - Refueling and Other Outage Activities (Partial Sample)

The inspectors evaluated Unit 1 Refueling Outage 1R27 activities from March 24, 2018, to

March 31, 2018. The inspectors completed inspection procedure Sections 03.01.a and

03.01.c.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (3 Samples)

(1) Unit 1 emergency feedwater solenoid operated control valve, CV-2646, establishment of

stroke time reference value and acceptance criteria on January 25, 2018

(2) Unit 1 and Unit 2 verified correct breaker alignment and indicated power availability for

the 161 kV offsite circuited with the 500 kV offsite inoperable during autotransformer

insulator repair on February 2, 2018

(3) Unit 1 train A reactor protection system and rod control system ac breaker surveillance

trip testing on February 27, 2018

In-service (1 Sample)

(1) Unit 2 service water motor operated valve, 2CV-1435-1, service water inlet to train A

shutdown heat exchanger on March 15, 2018

Reactor Coolant System Leak Detection (1 Sample)

(1) Unit 1 small increase of unidentified leakage on March 2, 2018

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (1 Sample)

The inspectors evaluated radiological hazards assessments and controls.

Instructions to Workers (1 Sample)

The inspectors evaluated worker instructions.

8

Contamination and Radioactive Material Control (1 Sample)

The inspectors evaluated contamination and radioactive material controls.

Radiological Hazards Control and Work Coverage (1 Sample)

The inspectors evaluated radiological hazards control and work coverage.

High Radiation Area and Very High Radiation Area Controls (1 Sample)

The inspectors evaluated risk-significant high radiation area and very high radiation area

controls.

Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)

The inspectors evaluated radiation worker performance and radiation protection technician

proficiency.

71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls

Implementation of ALARA and Radiological Work Controls (1 Sample)

The inspectors reviewed ALARA practices and radiological work controls by reviewing the

following activities and/or work packages:

(1) 2017-1070, core bore National Fire Protection Association (NFPA) 805 project and

support activities

(2) 2018-1414, as low as reasonable achievable (ALARA) activities during 1R27

(3) 2018-1420, scaffold installation/removal non-Locked High Radiation Areas - 1R27

(4) 2018-1430, reactor disassembly, reassembly, and support activities

(5) 2018-1900, emergent maintenance activities during 1R27

Radiation Worker Performance (1 Sample)

The inspectors evaluated radiation worker and radiation protection technician performance.

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

(8 Samples)

(1) IE01: Unplanned Scrams per 7000 Critical Hours Sample, Unit 1 and Unit 2,

(January 1, 2017, through December 31, 2017)

(2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample, Unit 1 and Unit 2,

(January 1, 2017, through December 31, 2017)

9

(3) IE04: Unplanned Scrams with Complications Sample, Unit 1 and Unit 2,

(January 1, 2017, through December 31, 2017)

(4) OR01: Occupational Exposure Control Effectiveness Sample (April 1, 2017, through

March 30, 2018)

(5) PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation

Manual (RETS/ODCM) Radiological Effluent Occurrences Sample (April 1, 2017,

through March 30, 2018)

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program

related to the following issues:

(1) Unit 2 train B service water inoperable due to strainer high differential pressure during

pre-screen cleaning following winter shad run on March 27, 2018

A finding associated with this inspection is documented in the Inspection Results section

below.

71153 - Follow-up of Events and Notices of Enforcement Discretion

Events (2 Samples)

(1) The inspectors evaluated licensees response to Unit 2 entry into loss of service water

abnormal operating procedure due to service water pump A and C strainer high

differential pressure alarm during pre-screen cleaning on January 19, 2018.

(2) The inspectors evaluated licensees response to Unit 1 and Unit 2 cyber security issues

on the business network on February 6, 2018.

Licensee Event Reports (LERs) (1 Sample)

The inspectors evaluated the following licensee event reports which can be accessed at

https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) LER 05000313/2016-002-00, Tornado Missile Vulnerability Resulting in Condition

Prohibited By Technical Specifications, on February 5, 2018

OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants

The inspectors evaluated the licensees operation of the independent spent fuel storage

installation (ISFSI) from October 30 to November 2, 2017, on-site at ANO, and conducted

an in-office review of additional documentation related to licensees maintenance of their

cask handling crane until January 2018.

10

The ANO ISFSI consisted of four ISFSI pads. ANO had loaded 24 canisters of the Energy

Solutions ventilated storage cask (VSC) VSC-24 design (Certificate of Compliance

No. 1007) from 1996 to 2003. Since that time, ANO had been loading HI-STORM 100S

Version C overpacks. ANOs ISFSI contained a total of 57 HI-STORM overpacks with

32 MPC-24 canisters and 25 MPC-32 canisters, at the time of the routine inspection. ANO

was currently loading canisters to the Holtec Certificate of Compliance 1014, Amendment 5,

and Final Safety Analysis Report (FSAR), Revision 7.

The ISFSI activities specifically reviewed during the on-site inspection and the subsequent

in-office review included:

(1) Evaluated and observed fuel selection and fuel loading operations.

(2) Reviewed the licensee's loading, processing, and heavy load procedures associated

with their current dry fuel storage campaign.

(3) Reviewed licensees corrective action program implementation for ISFSI operations

since the last routine ISFSI inspection which was completed in December 2015.

(4) Reviewed quality assurance (QA) program implementation, including recent QA

audits, surveillances, receipt inspection, and quality control activities.

(5) Reviewed documentation related to technical specification (TS) required operational

surveillance activities and Final Safety Analysis Report (FSAR) required annual

maintenance activities.

(6) Reviewed the licensees radiological monitoring data for the calendar years 2014,

2015, and 2016.

(7) Reviewed spent fuel documentation for the canisters loaded since the last routine

ISFSI inspection (Holtec Canister 48-57) to confirm the fuel met all TS requirements

for storage and transportation.

(8) Reviewed annual maintenance activities for heavy lifting components which included

special lifting devices and the sites cask handling crane (Auxiliary Building L-3

crane).

(9) Reviewed all 72.48 safety evaluations/screenings for changes made to the licensees

ISFSI operations in accordance with Inspection Procedure 60857 since the last

routine ISFSI inspection.

(10) Reviewed all changes made to the licensees 72.212 Report (Revision 10) in

accordance with Inspection Procedure 60856.1 since the last routine ISFSI

inspection.

Additionally, inspectors closed two unresolved items (URIs) from a routine ISFSI inspection

conducted in 2012 (see Inspection Results).

11

INSPECTION RESULTS

Failure to Establish Adequate Criteria for Flood Seal Testing

Cornerstone Significance Cross-cutting Report

Aspect Section

Mitigating Green [H.1] - 71111.01 -

Systems NCV 05000313/2018001-01 and Resources External

05000368/2018001-01 Flooding

Closed

The inspectors identified a Green finding and associated non-cited violation of Unit 1

Technical Specification 5.4.1.a and Unit 2 Technical Specification 6.4.1.a for the licensees

failure to establish the criteria for ensuring the necessary conditions existed for a successful

test of hatch flood seals. Specifically, Procedure OP 1402.240, Inspection of Watertight

Hatches, Revision 01, did not contain adequate guidance to ensure that the auxiliary building

was at a lower pressure than the turbine building such that puffing smoke on the turbine

building side would allow a seal leak to be detectable.

Description: As part of corrective actions to prevent recurrence for Yellow finding 05000313/2014009-01 and 05000368/2014009-01, the licensee improved the preventive

maintenance for flood seals on hatches that prevented flood waters from external sources

from entering the auxiliary building, where safety-related accident mitigation equipment was

located. These actions included a new testing protocol which established a pressure

differential across the seal, then puffed chemical smoke around the seal and observed for

leaks. Known as a smoke test, this method requires that air pressure inside the auxiliary

building be lower than turbine building air pressure so that when smoke is puffed around the

outside of the seal, the smoke would be pulled into the lower pressure area on the other side,

and leaks would be detectable.

On November 29, 2017, as part of a Confirmatory Action Letter Inspection, NRC inspectors

reviewed corrective actions and observed a smoke test of hatch 492. The inspector noted

that test personnel had checked that the auxiliary building ventilation was in a normal

alignment, but had assumed that this meant that pressure was lower on the auxiliary building

side of the hatch. When the licensee agreed to measure the pressure on each side of the

hatch, pressure was actually higher on the auxiliary building side such that leakage would not

have been detectable.

Procedure OP 1402.240, Inspection of Watertight Hatches, Revision 01, directed personnel

to ensure negative ventilation in the auxiliary building prior to start. However, the procedure

did not state how much pressure differential was needed or how this was to be measured.

The inspector determined that all six hatches that serve as flood barriers were previously

tested using the inadequate procedure. Upon discovery, the licensee took action to ensure

that a negative ventilation in the auxiliary building would be established and verified as part of

the procedure. When re-tested, all hatches passed the smoke test.

Corrective Action(s): The corrective action was to make changes to the procedure to

establish appropriate ventilation lineup and re-perform the smoke tests at all locations.

Corrective Action Reference(s): Condition Report CR-ANO-C-2017-04759

12

Performance Assessment:

Performance Deficiency: The licensees failure to establish adequate prerequisite criteria for

smoke testing flood seals on hatches is a performance deficiency.

Screening: The performance deficiency is more than minor because, if left uncorrected, it has

the potential to become a more significant safety concern. Specifically, because

Procedure OP 1402.240 did not have adequate instructions to ensure the appropriate

ventilation lineup, hatch flood seals would always pass the test regardless of whether the seal

would allow water to pass or not. Therefore, any flooding or pipe rupture could lead to water

ingress into the Unit 1 and Unit 2 auxiliary buildings affecting the availability of mitigating

equipment needed to respond to flooding. This finding affects the Mitigating Systems

Cornerstone.

Significance: The inspectors assessed the significance of the finding using Inspection

Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for

Findings At-Power, dated June 19, 2012. The inspectors determined that the finding had

very low safety significance (Green) because the equipment or safety function was not

completely failed or unavailable, and because the finding does not involve the total loss of

any safety function, identified by the licensee through a probabilistic risk assessment (PRA),

individual plant examination of external events (IPEEE), or similar analysis, that contributes to

external event initiated core damage accident sequences. Specifically, since the hatches

were confirmed to be leak tight after re-testing, no actual loss of function occurred.

Cross-cutting Aspect: This finding has a cross-cutting aspect in the area of human

performance associated with avoiding complacency, because the individuals failed to verify

that procedure prerequisites were met rather than assume they are met based on general

plant conditions.

Enforcement:

Violation: Technical Specification 5.4.1.a for Unit 1 and Technical Specification 6.4.1.a for

Unit 2 requires, in part, that written procedures be established, implemented, and maintained

covering the applicable procedures recommended in Appendix A to Regulatory Guide 1.33,

Quality Assurance Program Requirements, Revision 2, February 1978. Regulatory

Guide 1.33, Appendix A, Section 9.a, states that maintenance that can affect the performance

of safety-related equipment should be properly preplanned and performed in accordance with

written procedures, documented instructions, or drawings appropriate to the circumstances.

Contrary to the above, on November 29, 2017, the licensee failed to properly preplan and

perform maintenance that can affect the performance of safety-related equipment in

accordance with written procedures, document instructions, or drawings appropriate to the

circumstances. Specifically, Procedure 1402.240, Inspection of Watertight Hatches,

Revision 01, failed to include adequate details needed to not verify that the auxiliary building

was at a lower pressure than the turbine building prior to performing a smoke test of the flood

seal of hatch 492. Under the existing conditions, the test would have passed even with a

degraded seal. This condition had the potential to affect the performance of safety-related

mitigating equipment needed to respond to a flooding event.

13

Disposition: This violation is being treated as a non-cited violation, consistent with

Section 2.3.2.a of the Enforcement Policy, because it was very low safety significance

(Green) and was entered into the licensees corrective action program as Condition Report

CR-ANO-C-2017-04759.

Failure to Preplan and Perform Service Water Pre-Screen Maintenance

Cornerstone Significance Cross-cutting Report

Aspect Section

Mitigating Green [H.12] - Avoid 71152 -

Systems NCV 05000368/2018001-02 Complacency Annual

Closed Follow-up of

Selected

Issues

The inspectors reviewed a self-revealed, non-cited violation and associated finding of

Arkansas Nuclear One, Unit 2, Technical Specification 6.4.1.a, for the licensees failure to

properly preplan maintenance that can affect the performance of safety-related equipment.

Specifically, the licensee failed to properly preplan pre-screen cleaning maintenance, causing

the train B service water system to become inoperable.

Description: On January 19, 2018, ANO Unit 2 was operating in Mode 1 and making

preparations to clean the intake structure service water pre-screens in accordance with

Operating Procedure (OP) 2104.029, Service Water System Operations, Change 109. Two

operable trains of service water are required per Unit 2 Technical Specification 3.7.3.1,

Service Water System while in Mode 1.

The ANO Unit 2 service water system has stationary pre-screens between the traveling

screens and the pumps that must be manually hoisted out of the flow stream to be cleaned.

The configuration is such that debris can be knocked loose and fall back into the flow stream

during cleaning and enter both running pumps. The pre-screens are intended to catch small

debris that was not removed by the traveling screen so that the strainer baskets located

downstream of each pump do not get clogged. The discharge strainer basket design does

not have a self-cleaning feature.

Between January 16, 2018, through dayshift January 18, 2018, the licensee was aware that

they were experiencing a shad (fish) run in the intake canal. The pre-screen differential

pressure (D/P) had been exhibiting a rising trend due to debris buildup. During this

timeframe, the pre-screen and traveling screen D/P went from 3.00 inches of water to

6.75 inches of water. At 8:52 pm on January 18, 2018, the licensee received the service

water high differential pressure alarm and pre-screen D/P was 9.5 inches of water, with a

procedural requirement to initiate action to clean the pre-screens at 8 inches of water. Prior

to the licensee cleaning the pre-screens, D/P reached 18 inches of water. This rate of debris

buildup was unusual considering most D/P effects on the screen are witnessed on ANO

Unit 1 screens and not ANO Unit 2 screens. Based on past experience of slow build-up of

debris, the licensee delayed pre-screen cleaning until 4:14 a.m. on January 19, 2018, to avoid

having maintenance personnel exceed fatigue management limits.

During the lifting and removal of the first pre-screen for cleaning, fish were observed to be

falling off and entering the suction of the A (SW-P-A) and C (SW-P-C) service water pumps.

As a result, the Unit 2 control room received SW-P-A and SW-P-C discharge strainer high

differential pressure (D/P) annunciators. The SW-P-A discharge strainer D/P peaked at

12.8 psid, and the SW-P-C discharge strainer D/P peaked at 24.1 psid. The licensee entered

14

abnormal Operating Procedure 2203.022, Loss of Service Water, Revision 14, and

assessed the operability of train A and B service water systems. The swing pump suction

was aligned to the emergency cooling pond and the pump started so that a second train of

service water could be made available if needed.

Following an engineering evaluation, train B service water system was declared inoperable

due to exceeding the 20 psid operability limit for the SW-P-C strainer; train A service water

system remained operable throughout the event. Over the course of the rest of the day, the

licensee manipulated the service water system to clean the rest of the pre-screens and the

service water pump discharge strainers and reestablish train B service water system

operability. The train B service water system was declared operable at 10:10 p.m. on

January 19, 2018, at which time the Loss of Service Water procedure was exited. The

licensees short term corrective action was to implement a standing order for service water

pre-screens and traveling screens that required operations personnel to log both pre-screen

and traveling screen D/P and clean traveling screens at least weekly and pre-screens weekly.

The licensee documented this issue in Condition Report CR-ANO-C-2018-00299.

The inspectors noted that a similar event occurred on August 19, 2016. The D/P on the

train B service water pump strainer continued to rise until it reached the threshold at which

the performance of an engineering evaluation was required to determine the operability of the

B train of service water. This high D/P was attributed to fouling of the strainer caused by pre-

screen cleaning activities and delaying the start of the cleaning. Despite this event, the same

basic chain of events recurred on January 19, 2018. The inspectors pointed out that the pre-

screen design created an inherent risk of spilling debris into the open hole created by lifting

the pre-screens. With both trains in a normal alignment, most of the debris would enter both

pumps and begin to clog the discharge strainer. The inspectors questioned why this risk was

not avoided by proactively aligning one or both trains to the emergency cooling pond. The

licensee agreed to study this alternative as a possible corrective action.

Corrective Action(s): The immediate corrective action was to restore operability of the train B

service water system and institute a weekly pre-screen cleaning regiment.

Corrective Action Reference(s): Condition Report CR-ANO-C-2018-00299

Performance Assessment:

Performance Deficiency: The licensees failure to properly preplan pre-screen cleaning

maintenance that can affect the performance of safety-related equipment is a performance

deficiency. As a result, the performance of both trains of the safety-related service water

system were challenged, and train B was rendered inoperable.

Screening: The performance deficiency was more than minor because it adversely affected

the human performance attribute of the Mitigating Systems Cornerstone and the cornerstone

objective of ensuring the availability, reliability, and capability of systems that respond to

initiating events to prevent undesirable consequences. Specifically, the licensees failure to

properly preplan pre-screen cleaning maintenance resulted in the train B service water

system being rendered inoperable.

Significance: Using NRC Inspection Manual Chapter 0609, Appendix A, The Significance

Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2,

Mitigating Systems Screening Questions, the inspectors determined that the finding had

very low safety significance (Green) because it: was not a design deficiency; did not

15

represent a loss of system and/or function; did not represent an actual loss of function of at

least a single train for longer than its technical specification allowed outage time; and did not

result in the loss of a high safety-significant, nontechnical specification train.

Cross-cutting Aspect: The finding had a cross-cutting aspect in the area of human

performance associated with avoid complacency because the licensee did not plan for the

inherent risk with cleaning the pre-screens although cleaning of debris has previously

challenged the service water system. Specifically, the licensee did not effectively plan pre-

screen cleaning maintenance to avoid system impacts, and did not consider the rate of

increase in pre-screen differential pressure due to the winter fish runs in deciding when to

start the cleaning.

Enforcement:

Violation: Technical Specification 6.4.1.a requires, in part, that written procedures be

established, implemented, and maintained covering the applicable procedures recommended

in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 9.a of

Regulatory Guide 1.33, Appendix A, states that maintenance that can affect the performance

of safety-related equipment should be properly preplanned and performed in accordance with

written procedures, documented instructions, or drawings appropriate to the circumstances.

Contrary to the above, on January 19, 2018, the licensee failed to properly preplan and

perform maintenance as prescribed in Regulatory Guide 1.33. Specifically, the licensee failed

to preplan the cleaning of Unit 2 service water pre-screens prior to high debris loading of the

screens, and failed to place the service water system into an alignment that would have

avoided impacting the operability of this safety-related system.

Disposition: This violation is being treated as a non-cited violation, consistent with

Section 2.3.2.a of the Enforcement Policy, because it was very low safety significance

(Green) and was entered into the licensees corrective action program as Condition Report

CR-ANO-C-2018-00299.

Licensee Identified Non-Cited Violation 71124.01 -

Radiological Hazard

Assessment and

Exposure Controls

This violation of very low safety significant (Green) was identified by the licensee and has

been entered into the licensee corrective action program and is being treated as a non-cited

violation, consistent with Section 2.3.2.a of the Enforcement Policy.

Violation: Title 10 CFR 20.1501(a) requires that each licensee make or cause to be made

surveys that may be necessary for the licensee to comply with the regulations in

10 CFR Part 20, and that are reasonable under the circumstances to evaluate the magnitude

and extent of radiation levels, concentrations, or quantities of radioactive materials, and the

potential radiological hazards that could be present.

Contrary to the above, on August 7, 2017, the licensee failed to make necessary surveys of

the Unit 2, 2T-15 tank room, that were reasonable to evaluate the magnitude and extent of

radiation levels that could be present. Consequently, workers were allowed access to an

area with dose rates up to 1000 millirem per hour at 30 cm without a proper briefing or

oversight.

16

Significance: Using NRC Manual Chapter 0609, Appendix C, Occupational Radiation Safety

Significance Determination Process, the inspectors determined the finding to be of very low

safety significance (Green) because: (1) it was not associated with as low as is reasonably

achievable (ALARA) planning or work controls; (2) there was no overexposure; (3) there was

no substantial potential for an overexposure; and (4) the ability to assess dose was not

compromised.

Corrective Action Reference(s): CR-ANO-2-2017-04634 and CR-ANO-2-2017-05337

Unresolved Item Validation of the ANO data collected during the thermal 60855.1

(Closed) validation test and used in the Holtec analysis.

URI 7200013/2012001-02

Description: During the routine ISFSI inspection conducted on October 29 - November 1,

2012, an unresolved item (URI) was identified and documented in the routine ISFSI NRC

Inspection Report 05000313/20120008, 05000368/2012008, and 07200013/2012001

(ADAMS Accession No. ML13057A986).

The Holtec International HI-STORM 100 Certificate of Compliance (CoC) No. 1014,

Condition 9, required the performance of a one-time thermal validation test on the first cask

that exceeded 20 kW to validate the analytical methods and thermal performance predicted by

the licensing basis thermal model as described in Chapter 4 of the Holtec HI-STORM 100

FSAR. ANO was the first general licensee to load a canister exceeding 20 kW and, as such,

was required to perform the thermal validation test in accordance with License Condition 9.

During the NRC inspection in 2012, the inspectors identified that ANO had completed the test

using instrumentation that had not been controlled or calibrated in accordance with ANOs

quality assurance program. The NRC identified this failure to follow the ANOs quality

assurance program for the thermal validation test instrumentation as a non-cited violation of

10 CFR 72.164 (NCV 07200013/2012001-01) consistent with Section 2.3.2 of the NRC

Enforcement Policy. The validation of the data collected by the instrumentation used during

the test was considered indeterminate until the licensee was able to demonstrate that the

equipment was properly calibrated by a qualified vender on the licensees approved vendor

list. The resolution of this issue was tracked as an unresolved item

(URI 07200013/2012001-02).

ANO took corrective actions to verify that the data from the measuring instruments was

acceptable by sending the equipment to a qualified lab to verify the equipment was properly

calibrated. ANO was able to verify the calibration of the resistance temperature detectors

used in the test. The other equipment used in the test were DANTEC LVFA wind

tunnel 435-1010 anemometer probes which measured air velocities at very low rates of

speed. ANO sent these anemometers to multiple labs including Exelon Labs and National

Aeronautics and Space Administration (NASA) for calibration. Unfortunately, none of the labs

were able to successfully test the equipment to verify they were properly calibrated, and upon

return to ANO, the anemometers were broken in transit. ANO was unable to verify the validity

of the data collected during their thermal validation test.

Corrective Action Reference(s): CR-ANO-C-2013-00374, CR-ANO-C-2013-0575, and

CR-ANO-C-2013-00576

Closure Basis: Since the ANO staff were unable to validate the data collected for the thermal

validation test, as required by CoC License Condition 9, the required test will still need to be

17

performed. However, the NRC has concluded that the wording from CoC License Condition 9

(Amendments 5-9) was not suitable to provide adequate test data to confirm the Holtec

thermal analysis as described in the FSAR. The License Condition 9 required measuring air

velocity within the annulus area between the canister and the overpack. The data provided in

the ANO test was inconsistent and the test requirements listed in the CoC Amendments 5

through 9, License Condition 9, needed to be revised to provide more consistent data that

could be utilized by the vendor and the NRC to verify the analytical models from the FSAR.

On May 31, 2016, NRC issued CoC 1014, License Amendment 10, (ADAMS Accession

No. ML17237B994) which modified the License Condition 9 thermal validation test to measure

air velocity at the inlet vents and not the annulus area between the canister and the overpack.

The first general licensee to load a canister that exceeds 20 kW, under CoC 1014 License

Amendment 10, is required to perform the thermal validation test using the new method as

described in the license condition. This test will provide sufficient data for the vendor to

perform the required analysis and allow the NRC more stable results to review and conclude

on the validation of the thermal model as described in the FSAR. A licensee in another region

has described their intention of performing the required thermal validation test in the 2018

timeframe.

Unresolved Item Applicability of the ANO thermal validation test results to 60855.1

(Closed) other HI-STORM 100 overpack configurations.

URI 07200013/2012001-03

Description: On February 3, 2012, Entergy submitted a letter to the NRC informing the

agency of the completion of the thermal validation test (discussed above) and the completion

of the Holtec analysis (ADAMS Accession No. ML12038A177). On September 14, 2012,

Holtec also informed the NRC of the completion of the ANO thermal validation test and

provided a copy of Holtec Report HI-2114925 (ADAMS Accession No. ML12264A541) which

evaluated the test data. The Holtec report indicated that the thermal model utilized in the

licensing-based analysis methodology had predicted an air mass flow rate lower than the

values measured in the ANO thermal test and, as such, demonstrated an overall

conservatism of the licensing-based methodology, thereby confirming the suitability of the

methodology for demonstrating the thermal-hydraulics safety of the HI-STORM 100 cask

system and satisfying the requirement of Condition 9.

Holtec issued a statement to the other HI-STORM 100 general licensee users concerning the

ANO test on a HI-STORM 100S, Version C, overpack and whether the results could be

applied to other cask models of the 100 series. Holtec Licensing Position Paper HL-2011-01

was distributed to Holtec cask users dated August 5, 2011. Holtec concluded that the ANO

test data demonstrated the validity of the thermal models, and as such, the results of the ANO

test could be applied to any of the HI-STORM 100 overpack configurations. During a meeting

on December 18, 2012, between the NRC, ANO, and Holtec, the applicability of the ANO test

to the other HI-STORM overpacks was discussed extensively. A number of questions

remained as to the sensitivity of the test results to the various configurations of the overpack

dimensions and vent sizes. As such, the NRC needed to perform an independent evaluation

to confirm Holtecs position. The independent review performed by the NRC was tracked as

an unresolved item (URI 07200013/2012001-03).

Corrective Action Reference(s): CR-ANO-C-2013-00374, CR-ANO-C-2013-0575, and CR-

ANO-C-2013-00576

18

Closure Basis: As described above in URI 07200013/2012001-01, the NRC concluded that

the wording from CoC License Condition 9 (Amendments 5-9) was not suitable to provide

adequate test data to confirm Holtecs thermal methodology. On May 31, 2016, NRC issued

CoC 1014 License Amendment 10 (ADAMS Accession No. ML17237B994), which modified

the License Condition 9 thermal validation test to measure air velocity at the inlets and not the

annulus area between the canister and the overpack. The first general licensee to load a

canister that exceeds 20 kW under CoC 1014 License Amendment 10, is required to perform

the thermal validation test using the new method as described in the License Condition. Once

the new data is collected and analyzed by the general licensee and the vendor, the

information will be submitted to the NRC for an independent review.

A general licensee in another region has described their intention of performing the required

thermal validation test in the 2018 timeframe.

19

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On January 18, 2018, the inspector presented the results from the routine ISFSI inspection to

Ms. S. Pyle, Licensing Manager, and other members of the licensee staff.

On March 30, 2018, the inspector presented the radiation protection inspection results to

Mr. R. Anderson, Site Vice President, and other members of the licensee staff.

On April 4, 2018, the inspector presented the quarterly resident inspector inspection results to

Mr. J. Kirkpatrick, General Manager of Plant Operations, and other members of the licensee

staff.

On April 18, 2018, the inspectors presented the re-exit of the quarterly resident inspector

inspection results to Ms. S. Pyle, Regulatory Assurance Manager, and other members of the

licensee staff.

20

DOCUMENTS REVIEWED

71111.01 - Adverse Weather Protection

Miscellaneous Documents

Number Title Revision

M-2204 Piping & Instrument Diagram, Emergency Feedwater, 72

Sheet 4

Procedures

Number Title Revision

2104.036 Emergency Diesel Generator Operations 94

2106.006 Emergency Feedwater System Operations 97

2106.032 Unit Two Freeze Protection Guide 27

1402.240 Inspection of Watertight Hatches 2

Condition Reports (CR-ANO-)

C-2018-00050 1-2017-03673

71111.04 - Equipment Alignment

Miscellaneous Documents

Number Title Revision

CALC-91-E- ANO-2 EDG Room Ventilation 2

0090-02

CALC-91-R- 28

2013-01

EC-24964 U-2 Emergency Diesel Generator Cycle 20 Heat Exchanger

Thermal Performance Evaluation

EC-45962 2K-4A/B 2013 Emergency Diesel Heat Exchanger Thermal

Performance Test

EC-46332 U-2 Emergency Diesel Generator Thermal Performance

Test Review 2011

EC-52442 2014 2K-4A/B Thermal Performance Evaluation

EC-66265 U-2 SW Strainer D/P Spike Op Input 0

ER-ANO-2006-

0248-000

GL-89-13 SW System Problems Affecting Safety-Related Equipment

Attachment 1

Miscellaneous Documents

Number Title Revision

M-2204 Piping & Instrument Diagram, Emergency Feedwater, 72

Sheet 4

M-2210 Piping & Instrument Diagram, Service Water, Sheet 1 - 4 83

STM-2-42 SW and ACW Systems 38

Procedures

Number Title Revision

1403.191 Motor Testing Using MCE/EMAX 11, 12

2104.029 Service Water System Operations 109

2104.036 Emergency Diesel Generator Operations 94

2104.044 Ventilation System Operations 44

2106.006 Emergency Feedwater System Operations 97

Condition Reports (CR-ANO-)

1-2013-03239 1-2016-05663 1-2016-05675 1-2016-05676

1-2017-00186 1-2018-00132 2-2012-00762 2-2015-02748

2-2015-02879 2-2015-05329 2-2016-00035 2-2016-00550

2-2016-02987 2-2016-03206 2-2016-03918 2-2016-04462

2-2017-05291 2-2017-05919 2-2018-00157 2-2018-00165

2-2018-00168 C-2013-03165 C-2016-05226 C-2016-05445

C-2017-04059 C-2017-04069 C-2017-04775 C-2018-00277

C-2018-00441

Work Orders

52537116 52728726 497922-01

71111.05 - Fire Protection

Miscellaneous Documents

Number Title Revision/Date

Pre-Drill Brief - ASOTH-FP-FBDRLS 9

EC-52999 Justification for Additional Non-Q Battery Room Heating 00

A1-2

Miscellaneous Documents

Number Title Revision/Date

ER-ANO-2002- Justification for Temporary Non-Q Battery Room Heating January 30,

0145-00 2002

FBDRL-2018-03 Fire Drill March 9,

2018

Procedures

Number Title Revision

2106.032 Unit Two Freeze Protection Guide 27

71111.06 - Flood Protection Measures

Drawings

Number Title Revision

E-601 Electrical Plot Plan Outdoor Area, Sheet 1

1402.240 Inspection of Watertight Hatches 2

Work Orders

52747174

71111.11 - Licensed Operator Requalification Program and Licensed Operator

Performance

Procedures

Number Title Revision

OP-2202.001 Standard Post Trip Actions 16

OP-2202.002 Reactor Trip Recovery 11

OP-2203.009 Fire Protection System Annunciator Corrective Actions 32

OP-2203.025 RCP Emergencies 18

OP-2203.034 Fire or Explosion 21

71111.12 - Maintenance Effectiveness

Drawings

Number Title

234C7880F Induction Motor

A1-3

Miscellaneous Documents

Number Title Revision

117 Engineering Evaluation, SW Pumps 6

2015 U-2 SW System Health Report Q1, Q2, Q3, Q4

2016 U-2 SW System Health Report Q1, Q2, Q4

2017 U-2 SW System Health Report Q2

EC-28463 SW System 0

N 1000.006-P E-Doc, SW System Ops 53

TDG080 1710 Triclad Vertical Induction Motors 3

Procedures

Number Title Revision

1304.125 Unit 1 RPS-A/CRD Breaker Trip Test 26

1309.013 Flow Rate Data

2104.029 SW System Ops 109

2203.022 Loss of SW Tech Guidelines 14

2311.002 Flow Rate Data

2411.102 U-2 Slide Gate and SW Bay Cleaning/Inspection

EN-DC-204 Maintenance Rule Scope and Basis 4

EN-DC-205 Maintenance Rule Monitoring 6

EN-FAP-OM-012 Prompt Investigation and Notifications, Attn. 7.4 9

EN-LI-118 ANO Response to Cold Weather Shad Runs 25

1402.240 Inspection of Watertight Hatches 2

Condition Reports (CR-ANO-)

1-2017-00965 2-2014-02814 2-2015-00083 2-2015-00129

2-2015-00268 2-2016-01808 2-2016-02351 2-2016-02611

2-2017-01162 2-2017-05280 2-2017-05281 2-2017-05329

2-2017-05759 2-2018-00044 2-2018-00045 2-2018-00157

2-2018-00300 2-2018-00445 2-2018-00797 C-2017-00287

C-2018-00299 C-2018-01623 1-2017-03673

A1-4

Work Orders

189034 435369 453805 468095 486027

489032 51803722 52652306 52711156 52713201

52715932 52728009 52766896 52784316

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Miscellaneous Documents

Number Title Revision

COPD-024 Risk Assessment Actions 64

Procedures

Number Title Revision

1107.001 Electrical System Operations 115

2104.029 Service Water System Operations 109

2203.003 CEA Malfunction 24

EN-FAP-OM-021 Critical Decision Procedure 5

EN-OP-119 Protected Equipment Postings 9

EN-WM-104 On Line Risk Assessment 16

Condition Reports (CR-ANO-)

C-2018-00474 C-2018-00475

Work Orders

490410

71111.15 - Operability Determinations and Functionality Assessments

Drawings

Number Title

A2001S01 ANO 500/161KV SW STA Station One-Line In-Service

Diagram

E-2100 Schematic Diagram Diesel Generator 2K4A ACB 152-308

E-2276 Schematic Diagram Service Water Pump 2P4B

E-2361 Schematic Diagram Containment Cooling 2VSF1A

E-2361 Schematic Diagram Containment Cooling 2VSF1B

A1-5

Miscellaneous Documents

Number Title Date

00-R-2011-01 Calculation

OPS-152A SU1 Outage Checklist - Unit 1 - 72-Hour TC August 29,

2013

OPS-152B SU3 Outage Checklist - Unit 2 - 72-Hour TC August 29,

2013

Procedures

Number Title Revision

1106.006 Emergency Feedwater Pump Operation 100, 101, 102

Condition Reports (CR-ANO-)

1-2000-00068 1-2017-01820 1-2018-00086 2-2000-00074

2-2018-00055 2-2018-00065 2-2018-00088 C-2018-00389

C-2018-00474 C-2018-00475

Work Orders

490410-16

71111.18 - Plant Modifications

Miscellaneous Documents

Number Title Revision/Date

CALC-86E-0020- 1E Station Battery 2D11 Duty Cycle and Sizing Calculation 18

01

EC-52999 Justification for Additional Non-Q Battery Room Heating 00

ER-ANO-2002- Justification for Temporary Non-Q Battery Room Heating January 30,

0145-00 2002

STM 2-32-5 125 VDC Electrical Distribution 25

Procedures

Number Title Revision

2106.032 Unit Two Freeze Protection Guide 27

A1-6

Condition Reports (CR-ANO-)

2-2003-00041 2-2014-00345

Work Orders

490646

71111.19 - Post-Maintenance Testing

Procedures

Number Title Revision

2304.237 Post Maintenance Verification 16

Condition Reports (CR-ANO-)

1-2018-01107 2-2018-00356

Work Orders

494916

71111.22 - Surveillance Testing

Miscellaneous Documents

Number Title Revision/Date

CALC-95-R-

0014-02-01

MWO50235000

MWO50235239

MWO50235641

OPS-152A SU1 Outage Checklist - Unit 1 - 72-Hour TC August 29,

2013

OPS-152B SU3 Outage Checklist - Unit 2 - 72-Hour TC August 29,

2013

SEP-ANO-1- ANO-1 Inservice Testing Basis Document 3

IST-1

Procedures

Number Title Revision

1104.209 SW Pump Performance Curves

A1-7

Procedures

Number Title Revision

1106.006 Emergency Feedwater Pump Operation 100, 101, 102

1107.001A Unit 1 XFMR Outage Checklist 115

1304.125 Unit 1 RPS-A/CRD Breaker Trip Test 26

2104.029 SW Pump Performance Curves

Condition Reports (CR-ANO-)

1-2009-01820 1-2017-00965 1-2018-00086 1-2018-00631

2-2017-05885 C-2018-00474

Work Orders

52747144

71124.01 - Radiological Hazard Assessment and Exposure Controls

Air Sample Surveys

Number Title Date

AS-ANO-2018- RAB 10 - P36 A Makeup Pump Tear Down March 2,

04648 2018

AS-ANO-2018- RAB 11 - AMS-4 Alarm March 7,

04660 2018

AS-ANO-2018- RAB 121 - Replace 2RE - 8221-2 Blower Pump UNPR March 9,

04665 2018

Audits and Self-Assessments

Number Title Date

LO-ALO-2017- Self-Assessment: Radiation Safety - Hazard Assessment March 22,

00025 and Airborne Controls 2017

QA-14/15-2017- November 6,

Combined Radiation Protection and Radwaste

ANO-01 2017

Miscellaneous Documents

Number Title Date

NSTS Annual Inventory Reconciliation Report January 11,

2018

ANO Alpha Hazard Evaluation May 3, 2017

A1-8

Miscellaneous Documents

Number Title Date

ANO-2017-0067 Spent Fuel Pool Inventory - Non-Fuel Items August 22,

2017

ANO-2017-0093 2017 Radiation Energy Distribution Evaluation December 7,

2017

52742701 Annual Inventory of Non-Installed Radioactive Sources February 20,

2018

52745968 Semi Annual Leak Test of Sealed Sources February 15,

2018

Procedures

Number Title Revision

EN-RP-100 Radiation Worker Expectations 12

EN-RP-101 Access Control for Radiologically Controlled Areas 14

EN-RP-102 Radiological Control 5

EN-RP-104 Personnel Contamination Events 10

EN-RP-105 Radiological Work Permits 18

EN-RP-106 Radiological Survey Documentation 7

EN-RP-108 Radiation Protection Posting 20

EN-RP-109 Hot Spot Program 5

EN-RP-121 Radioactive Material Control 14

EN-RP-123 Radiological Controls for Highly Radioactive Objects 1

EN-RP-143 Source Control 13

EN-RP-152 Conduct of Radiation Protection 3

Radiation Surveys

Number Title Date

1609-0457 U1 AUX 335 EL - F3A/F3B Filter Rooms September

19, 2016

1703-0336 U1 AUX Bldg - T-15 Tank Room March 14,

2017

1801-0490 U1 AUX 335 EL F2 Seal Injection Filter Room January 31,

2018

1802-0204 Semi Annual Source Leak Test February 14,

2018

A1-9

Radiation Work Permits

Number Title Revision

20181401 Radiation Protection Activities During 1R27 00

20181407 Decontamination Activities During !R27 (Bulk Work) 00

20181412 1R27 Locked High Radiation Area Activities (Bulk Work) 01

20181425 RCP Motor Maintenance During 1R27 00

20181430 Reactor Disassembly/Re-Assembly, and Support Activities 00

20181432 De-Fuel & Re-Fuel the Reactor 00

20182053 Spent Fuel Activities - Unit 2 00

Condition Reports (CR-ANO-)

1-2018-00585 1-2018-00997 1-2018-01273 2-2017-01634

2-2017-04273 2-2017-04634 2-2017-05337 2-2017-06115

C-2017-00890 C-2017-00946 C-2017-01105 C-2017-03822

C-2017-03929 C-2018-01264

Fleet Condition Reports (CR-HQN-)

2017-00179 2017-00848 2017-00974

71124.02 - Occupational ALARA Planning and Controls

ALARA Planning, In-Progress Reviews, and Post-Job Reviews

Number Title Date

20171070 Core Bore NFPA 805 Project and Support Activities March 6,

2018

20181070 Core Bore NFPA 805 Project and Support Activities March 5,

2018

20181430 Reactor Disassembly, Reassembly, and Support Activities June 17,

2017

Audits and Self-Assessments

Number Title Date

LO-ALO-2017- Self-Assessment: Radiation Safety - ALARA & Dose September

00023 Assessment 11, 2017

QA-14/15-2017- Quality Assurance Audit: Combined Radiation Protection November 6,

ANO-01 and Radwaste 2017

A1-10

Miscellaneous Documents

Number Title Date

Letdown Heat Exchanger (E-29A/B) Flush Plan March 28,

2018

TSR 18-1-063 Letdown Heat Exchangers, E-29A and E-29B December 7,

2017

TSR 18-1-064 RBD-11A & RBD-12A / Makeup System December 7,

2017

TSR 18-1-123 Letdown Cooler E-29A&B Inlet/Outlet Isolation December 7,

2017

Procedures

Number Title Revision

EN-RP-105 Radiological Work Permits 18

EN-RP-110 ALARA Program 14

EN-RP-110-03 Collective Radiation Exposure Guidelines 4

EN-RP-110-04 Radiation Protection Risk Assessment Process 7

EN-RP-110-06 Outage Dose Estimating and Tracking 1

Radiation Work Permits

Number Title Revision

20171070 Core Bore NFPA 805 Project and Support Activities 03

20181070 Core Bore NFPA 805 Project and Support Activities 03

20181401 Radiation Protection Activities During 1R27 00

20181414 ALARA Activities During 1R27 00

20181420 Scaffold Installation / Removal Non-LHRAs - 1R27 00

20181430 Reactor Disassembly, Reassembly, and Support Activities 00

20181900 Emergent Maintenance Activities During 1R27 00

Condition Reports (CR-ANO-)

1-2018-00336 1-2018-00508 1-2018-00849 2-2017-05526

C-2017-04230 C-2017-04551 C-2017-04692 C-2018-00851

A1-11

Fleet Condition Reports (CR-HQN-)

2017-01791

71151 - Performance Indicator Verification

Procedures

Number Title Revision

EN-LI-114 Regulatory Performance Indicator Process 7, 8

71152 - Problem Identification and Resolution

Miscellaneous Documents

Number Title Revision

EC-66265 U-2 SW Strainer D/P Spike Op Input 0

ER-ANO-2006-

0248-000

GL-89-13 SW System Problems Affecting Safety-Related Equipment

Condition Reports (CR-ANO-)

1-2013-03239 1-2016-05663 1-2016-05675 1-2016-05676

1-2017-00186 1-2018-00132 2-2012-00762 2-2015-02748

2-2015-02879 2-2015-05329 2-2016-00035 2-2016-00550

2-2016-02987 2-2016-03206 2-2016-03918 2-2016-04462

2-2017-05291 2-2017-05919 2-2018-00157 2-2018-00165

2-2018-00168 C-2013-03165 C-2016-05226 C-2016-05445

C-2017-04059 C-2017-04069 C-2017-04775 C-2018-00277

C-2018-00441 C-2018-0299

71153 - Follow-up of Events and Notices of Enforcement Discretion

Miscellaneous Documents

Number Title

CALC-16-E- Tornado Missile Shield for Door 77, Room 144

0017-01

EC 67019 Door 77, room 144 Tornado Generated Missile Barrier

ECN 73255 Resolution of Rebar Interferences for DR-77 Missile Barrier

A1-12

Miscellaneous Documents

Number Title

LER Tornado Missile Vulnerability Resulting in Condition

05000313/2016- Prohibited By Technical Specifications

002-00

Condition Reports (CR-ANO-)

1-2016-01788

Other Activities

Design Basis Documents

Number Title Revision/Date

72.212 72.212 Report for ANO ISFSI 10

Area-TLD Report Review of 2014 Area Monitoring Results (1st/2nd half) February

2015

Area-TLD Report Review of 2015 Area Monitoring Results (1st/2nd half) February

2016

Area-TLD Report Review of 2016 Area Monitoring Results (1st/2nd half) February

2017

CoC 1014 CoC and Technical Specifications for HI-STORM 100 Amendment 5

ISFSI FSAR HI-STORM 100 ISFSI Final Safety Analysis Report 7

LTR-PAR-17-081 Evaluation of XSAM Periodic Test ANO, Two Block November 20,

2017

WTHQN-2015- Surveillance Activity Report April 15, 2015

277

WTHQN-2015- Surveillance Activity Report April 15, 2015

605

WTHQN-2016- Surveillance Activity Report December 9,

774 2016

Miscellaneous Documents

Number Title Date

ANO-1708-0273 Survey of Dry Fuel Pad August 16,

2017

ANO-1708-0279 Survey of CTF Dry Fuel Storage Pad August 16,

2017

A1-13

Miscellaneous Documents

Number Title Date

WTHQN-2016- Surveillance Activity Report December 9,

775 2016

WTHQN-2016- Surveillance Activity Report February 16,

776 2016

WTHQN-2016- Surveillance Activity Report December

777 15, 2016

WTHQN-2017- Surveillance Activity Report January 25,

111 2017

WTHQN-2017- Surveillance Activity Report April 27, 2017

372

WTHQN-2017- Surveillance Activity Report June 9, 2017

453

Procedures

Number Title Revision

1015.003B Unit Two Operations Logs 80

EDR-1 Generic Licensing Topical Report for L-3 Crane 3

EN-DC-215 Fuel Selection for Holtec Dry Cask Storage for Canisters 48 6

through 57

EN-LI-100 Process Applicability Determination 20

EN-LI-101 10 CFR 50.59 Evaluations 15

EN-LI-112 10 CFR 72.48 Evaluations 12

EN-LI-115 HI-STORM 100 ISFSI Licensing Document Preparation and 7

Control

EN-RP-210 Area Monitoring Program 1

OP-3403.004 HI-STORM 100 System Equipment Preparation 18

OP-3403.005 HI-STORM 100 System Loading Operations 40

OP-3403.008 HI-TRAC and MPC Preparations for Fuel Loading 1

OP-3403.009 MPC Receipt Inspections 1

OP-3403.010 HI-STORM Overpack Receipt Inspections 1

OP-3406.005 Hi-STORM and HI-TRAC Transport Operations 14

OP-3406.006 Forced Helium Dehydration System Operations 9

OP-3406.007 Supplemental Cooling System Operations 8

A1-14

72.48 Evaluations

Number Title Date

DFS-15-001 72.48 Evaluation, Foreign Material December

22, 2015

DFS-16-001 72.48 Evaluation, Application of Concrete Sealant January 21,

2016

Condition Reports (CR-ANO-)

1-2017-3441 1-2017-3445 1-2017-3447 1-2017-3448

1.2017-3449 1.2017-3450 1-2017-3451 1-2017-3538

1-2017-3540 1-2017-3541 1-2017-3555 1-2016-0403

2-2015-2420 2-2016-0359 2-2016-2071 C-2015-0849

C-2015-0918 C-2015-0969 C-2015-1185 C-2015-2297

C-2015-2765 C-2015-3387 C-2015-4664 C-2015-4693

C-2015-4905 C-2015-4971 C-2016-0038 C-2016-0834

C-2016-0848 C-2016-1344 C-2016-2844 C-2016-3647

C-2016-4458 C-2017-2506 C-2017-2850

Engineering Changes

EC-15295 EC-37094 EC-42379 EC-45077 EC-48646

EC-48806 EC-52044 EC-52619 EC-54103 EC-59072

EC-63881 EC-73641

Work Orders

00065585 00408695 00419603 00439666 00479654

00488244 00489244 52393253 52576506 52629825

52629826 52638961 52663017 52667631 52687172

52687173 52701892 52707684 52719037

A1-15

The following items are requested for the

Occupational Radiation Safety Inspection

Arkansas Nuclear One

March 26 thru 30, 2018

Integrated Report 2018001

Inspection areas are listed in the attachments below.

Please provide the requested information on or before March 9, 2018.

Please submit this information using the same lettering system as below. For example, all

contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled

1- A, applicable organization charts in file/folder 1- B, etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at

least 30 days later than the on-site inspection dates, so the inspectors will have access to the

information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please contact Natasha Greene at (817) 200-1154 or

natasha.greene@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget,

control number 3150-0011.

Attachment 2

1. Radiological Hazard Assessment and Exposure Controls (71124.01) and

Performance Indicator Verification (71151)

Date of Last Inspection: April 10, 2017

A. List of contacts and telephone numbers for the Radiation Protection Organization Staff

and Technicians

B. Applicable organization charts

C. Audits, self-assessments, and LERs written since date of last inspection, related to this

inspection area

D. Procedure indexes for the radiation protection procedures

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews

the procedure indexes.

1. Radiation Protection Program Description

2. Radiation Protection Conduct of Operations

3. Personnel Dosimetry Program

4. Posting of Radiological Areas

5. High Radiation Area Controls

6. RCA Access Controls and Radiation Worker Instructions

7. Conduct of Radiological Surveys

8. Radioactive Source Inventory and Control

9. Declared Pregnant Worker Program

F. List of corrective action documents (including corporate and sub-tiered systems) since

date of last inspection

a. Initiated by the radiation protection organization

b. Assigned to the radiation protection organization

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

If not covered above, a summary of corrective action documents since date of last

inspection involving unmonitored releases, unplanned releases, or releases in which any

dose limit or administrative dose limit was exceeded (for Public Radiation Safety

Performance Indicator verification in accordance with IP 71151)

G. List of radiologically significant work activities scheduled to be conducted during the

inspection period (If the inspection is scheduled during an outage, please also include a

list of work activities greater than 1 rem, scheduled during the outage with the dose

estimate for the work activity.)

H. List of active radiation work permits

A2-2

I. Radioactive source inventory list

a. All radioactive sources that are required to be leak tested

b. All radioactive sources that meet the 10 CFR Part 20, Appendix E, Category 2

and above threshold. Please indicate the radioisotope, initial and current activity

(w/assay date), and storage location for each applicable source.

J. The last two leak test results for the radioactive sources inventoried and required to be

leak tested. If applicable, specifically provide a list of all radioactive source(s) that have

failed its leak test within the last two years

K. A current listing of any non-fuel items stored within your pools, and if available, their

appropriate dose rates (Contact / @ 30cm)

L. Computer printout of radiological controlled area entries greater than 100 millirem since

the previous inspection to the current inspection entrance date. The printout should

include the date of entry, some form of worker identification, the radiation work permit

used by the worker, dose accrued by the worker, and the electronic dosimeter dose

alarm set-point used during the entry (for Occupational Radiation Safety Performance

Indicator verification in accordance with IP 71151).

A2-3

2. Occupational ALARA Planning and Controls (71124.02)

Date of Last Inspection: November 6, 2017

A. List of contacts and telephone numbers for ALARA program personnel

B. Applicable organization charts

C. Copies of audits, self-assessments, and LERs, written since date of last inspection,

focusing on ALARA

D. Procedure index for ALARA Program

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews

the procedure indexes.

1. ALARA Program

2. ALARA Committee

3. Radiation Work Permit Preparation

F. A summary list of corrective action documents (including corporate and sub-tiered

systems) written since date of last inspection, related to the ALARA program. In addition

to ALARA, the summary should also address Radiation Work Permit violations,

Electronic Dosimeter Alarms, and RWP Dose Estimates

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G. List of work activities greater than 1 rem, since date of last inspection,

Include original dose estimate and actual dose.

H. Site dose totals and 3-year rolling averages for the past 3 years (based on dose of

record)

I. Outline of source term reduction strategy

J. If available, provide a copy of the ALARA outage report for the most recently completed

outages for each unit

K. Please provide your most recent Annual ALARA Report.

A2-4

ML18120A214

SUNSI Review Non-Sensitive Publicly Available Keyword:

By: NFO/rdr Sensitive Non-Publicly Available NRC-002

OFFICE SPE:DRP/E C:DRP/E

NAME JDixon NOKeefe

SIGNATURE /RA/ /RA/

DATE 4/30/18 4/30/18

ML18120A037

SUNSI Review Non-Sensitive Publicly Available Keyword:

By: NFO/rdr Sensitive Non-Publicly Available NRC-002

OFFICE SPE:DRP/E BC:DRP/E BC:DRP/E

NAME JDixon LBrookhart NOKeefe

SIGNATURE /RA/ /RA-E/ /RA/

DATE 4/30/18 4/27/18 4/30/18