ML20202E288

Forwards Insp Repts 50-313/97-21 & 50-368/97-21 on 971027-31 & 1110-14,NOV & Excercise of Discretion.Violation Involved Failure to Include vendor-recommended Efs Flow Limits in Operating Procedure

ML20202E288
Person / Time
Site:	Arkansas Nuclear
Issue date:	02/06/1998
From:	Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Hutchinson C ENTERGY OPERATIONS, INC.
Shared Package
ML20202E294	List: ML20202E288 ML20202E320 ML20202E340
References
50-313-97-21, 50-368-97-21, EA-97-574, EA-98-053, EA-98-53, NUDOCS 9802180114
Download: ML20202E288 (6)

See also: IR 05000313/1997021

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EA 97-574 l

EA 98-053

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C. Randy Hutchinson, Vice President -

Operations

Arkansas Nuclear One

Entergy Operations, Inc.

1448 S.R. 3S3

Russellville, Arkansas 72801-0967

SUBJECT: NRC INSPECTION REPORT 50-313/97-21; 50-368/97-21, NOTICE OF

VIOLATION, AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Hutchinson:

An NRC inspection was conducted October 27-31 and November 10-14,1997, at your Arkansas

Nuclear One, Units 1 and 2, reactor facilities, and included offsite review of documents during

the period November 17,1997, to January 5,1998. The enclosed report presents the scope

and results of that inspection.

This inspection focused on the review of previous NRC inspection findings. The report discusses

several violations of NRC requirements. Examples of inadequate control of design calculations

were identified in one of the violations. Separately, the items were of miriimal safety

significance, but collectively, they indicated a potential problem with existing design calculations.

We were encouraged that you had identified weaknesses in this area and were in the process of

implementing comprehensive corrective actions as a result of a qua.lity assurance team audit in

1996. These actions should iraprove the quality of future desir,n calculations. However, we

were concerned that your corrective actions did not appear to include a review to determine the i

status of the technical content of your existing calculations of record. We considered this to be a j

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weakness in your overah approach. f  ;

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Another violation involved a failure to include vendor-recommended emergency feedwater L

system flow limits in an operating procedure. This violation was of concern because the failure H

to install procedural limits resulted in at least two occasionc where the effects of the maximum  !

flow limits being exceeded were not evaluated. Although this did not create an actual safety (  :

concern in this instance, other failures to implement manufacturers' recommendations could

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have safety implications.

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EntErgy Operations, Inc. 2 -

These violations are cited in the enciooed Notice of Violation (Notice) and the circumstances

surrounding the violations are desenbod in detail in the enclosed report. Please note that you

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

Notice when preparing your response, The NRC will use your response, in part, to determine -

l whether further enforcement action is t'ocessary to ensure compliance with regulatory

. requirements.

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Another identified problem involved five examples of the failure to property update the Final

Safety Analysis Report with current design inSrmation. This problem would normally have been

p - identiflod as a Severity Level IV violation and would have been cited because it was identified by

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- the NRC. However, the NRC is exercising discretion in accordance with Section Vll.B.3 of the ,

L Enforcement Policy and is not taking formal enforcsment action (EA 98-053). Specifically, the

l NRC recognizes that you have underway a comprehensive program to review and update your

Final Safety Analysis Report. This program was described in your letter to the NRC dated

May 7,1997. It is NRC's view, given the scope and schedule for completing this review, that

j these discrt ies would likely have been identified through your final safety analysis review

L Program.

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In addition, three apperent violations were identified (EA 97 574) and are being considered for

,  : escalated enforcement action in accordance with the " General Statement of Policy and

i Procedure for NRC Enforcement Actions"(Enforcement Policy), NUREG-1600. These violations

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are associated with events beginning Cecember 4,1996, when the pressure and vacuum rulief

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valve on the borated water storage tank was removed for maintenance and testing. During the

process of installing three temporary coverings on the tank flange, your activities. appeared to be

in violation of three regulatory requirements; including 10 CFR 50.5g, for failure to adequat3ly

, evaluate the safety concems related to the temporary coverings; 10 CFR Part 50, Aopendix B,

l Criterion Ill, " Design Control," for failure to initiate the proper design control measura, and

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--10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," fo_r failure to

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follow the vacuum relief valve test procedure plant condition requirements. Accordingly, no

n  : Notice of Violation is presently being issued for these inspection findings. In addition, please be

advised that the number and characterization of apparent violations described in the enclosed

L inspection report may change as a result of further NRC review.

L The NRC is concemed about the apparent violations, because of the potential safety

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' implications associated with the installation of a Herculite plastic covering placed over the

vacuum relief valve flange. The violations also suggest a breakdown of controls established to

ensure that only appropriate maintenance is performed during power operations and that

b  : appropriate safety evaluations are performed when temporary alterations are installed. The '

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sequence of events began with the use of the borated water storage tank vacuum relief valve

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test procedure Juring power operations, although it was only intended to be used during

. refueling outage conditions, and later extended to the failure to use your temporary alteration

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program for a series of temporary coverings on the borated water storage tank vacuum relief

valve flange. As a result of bypassing the temporary alteration program, safety evaluations of

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the temporary covering configurations were not performed as required. Our primary safety

concern is focused on the 30-hour period during which a Hercuhte plastic bag was placed over

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Entergy Operations, Inc. -3-

the valve flange, it appeared from your extensive testing and evaluation of this configuration

(showing that the borated water storage tank was in a poten 'ly degraded state) that the initial

use of engineering judgement, by itself, to consider this confi ation operable was

inappropriate.

A predecisional enforcement conference to discuss these apparent violations has been

scheduled for February 20,1998. The decision to hold a predecisional enforcement conference

does not mean that the NRC has determined that violations have occurred or that enforcement

action will be taken. This conference is being held to obtain information to enable the NRC to

make an enforcement decision, such as a common understanding of the facts, root causes,

missed opportunities to identify the apparent violations sooner, corrective actions, significance of

the issuas, and the need for lasting and effective corrective action in particular, we expect you

to address the operability of the borated water storage tank during the 30-hour period that the

Hercu"3 plastic bag was installed over the vacuum relief valve flange and the effect on operator

actions during design basis events where the plastic bag could have affected borated water

storage tank level indication. You have provided several evaluations and calculations

supporting your operability determination, and we will confirm our understanding of your

operability determination during the conference.

In addition, this is an opportunity for you to point out any errors in our inspection report and for

you to provide any information concerning your perspectives on 1) the severity of the violations,

2) the application of the factors that the NRC considers when it determines the amount of a civil

penalty that may be assessed in accordance with Section VI.B.2 of the Enforcement Policy, and

3) any other application of the Enforcement Policy to this case, including the exercise of

discretion in accordance with Section Vll. This conference will be open to public observation.

You will be advised by separate correspondence of the results of our deliberations on this

matter. No response regarding the apparent violations is required at this time.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its

enclosure (s), and your response will be placed in the NRC Public Document Room (PDR). To

the extent possible, your r_esponse should not include any personal privacy, proprietary, or

safeguards information so that it can be placed in the PDR without redaction.

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l Should you have any questions concerning this inspection, we will be pleased to discuss them

l with you.

Sincerely,

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l h Arth r TI Howell111, Director

j Division of Reactor Safety

Docket Nos.: 50-313;50-368

License Nos.: DPR-51; NPF-6

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Entergy Operations, Inc. -4

Enclosures:

1. Notice of Violation

2. NRC Inspection Report

50-313/97-21; 50-368/97-21

cc w/ enclosures:

Executive Vice President ,

& Chief Operating Officer

Entergy Operations, Inc.

P.O. Box 31995

Jackson, Mississippi 39286-1995

Vice President

Operations Support

Entergy Operations, Inc.

P.O. Box 31995

Jackson, Mississippi 39286

Manager, Washington Nuclear Operations

ABB Comuustion Engineering Nuclear

Power

12300 Twinbrook Parkway, Suite 330 .

Rockville, Maryland 20852

County Judge of Pope County

Pope County Courthouse

Russellville, Arkansas 72801

Winston & Strawn

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1400 L Street, N.W.

Washington, D.C. 20005-3502

David D. Snellings, Jr., Director

Division of Radiation Control and

Emergency Management

Arkansas Department of Health

4815 West Markham Street, Mail Slot 30

Little Rock, Arkansas 72205-3867

Manager

Rockville Nuclear Licensing

Framatome Technologies

1700 Rockville Pike, Suite 525

Rockville, Maryland 20852

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