ML20217N271

Notice of Violation from Insp on 980302-11.Violation Noted: Engineering Technique Specification Sheet Etss 4 Instructed Outage 2P98 Eddy Current Analysts to Use Phase Rotation Setting Inappropriate for Plus Point Probe

ML20217N271
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/02/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20217N251	List: ML20217N248 ML20217N271 ML20217N302
References
50-313-98-12, 50-368-98-12, NUDOCS 9804090060
Download: ML20217N271 (3)

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ENCLOSURE 1 NOTICE OF VIOLATION Entergy Operations, Inc. Docket Nos.: 50-313,50-368 Arkansas Nuclear One License Nos.: DPR-51; NPF-6 During an NRC inspection conducted on March 2-11,1998, two violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

1. Criterion IX of Appendix B to 10 CFR Part 50 requires, in part, that measures shall be established to assure that special processes, including nondestructive testing, are controlled and accomplished using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements.

Paragraph 6.7 of Procedure 5000.018, " Steam Generator Integrity Program Administration," Revision 0, requires, in part, that the inservice inspection of the steam generator tubing is in accordance with Reference 3.1.8. Reference 3.1.8 in Procedure 5000.018, Revision 0, is documented as "EPRI PWR Steam Generator Examination Guidelines, Latest Revision."

Section 2.3 of the Electric Power Research Institute "PWR Steam Generator Examination Guidelines," Report EPRI TR-107569-V1R5 dated September 1997, includes in the responsibilities of the steam generator examination and engineering function to utilize qualified eddy current examination techniques that are in accordance

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with Appendix H of the guidelines. j Contrary to the above, Engineering Technique Specification Sheet ETSS #4 instructed the Outage 2P98 eddy current analysts to use a phase rotation setting that was )

inappropriate for the plus point probe and inconsistent with the Appendix H of the Electric Power Research Institute FWR Steam Generator Examination Guidelines ,

qualified setting. Specifically, ETSS # 4 instructed the analyst to adjust phase )

rotation so that probe motion was horizontal, whereas the Appendix H qualification, j ETSS # 96402 odsec2. doc, specified a phase rotation setting of 15* for 40 percent j through-wall circumferential and axial inside diameter notches. j This is a Severity Level IV violation (Supplement l} (50-368/9812-02).

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2. Criterion V of Appendix B to 10 CFR Part 50 requires, in part, that activities affecting l quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings, of a type appropriate to the circumstances.

Paragraph 5.4.5 of Engineering Standard HES-72,"ANO Eddy Current Data Acquisition Guideline," Revision 0, states, in part, " . Changes made to this standard should be completed by using a standard change notice (SCN) form found in Reference 3.1.11.

If an SCN is not used, a revision to the Engineering Standard is required."

9804090060 980402 PDR ADOCK 05000313 Q PDR

Reference 3.1.11 in Engineering Standard is documented as "5000.011A, Engineering' Standard Control."

Contrary to the above, a change wss made to the guidance contained in Engineering Standard HES-72, Revision 0, pertaining to the voltage normalization practice to be used during Outage 2P98 for 0.11d-inch pancake coil examinations, without either issue of an SCN or revision of the engineering standard. Specifically, Engineering Standard HES-72, Revision 0, requ' red the analysts to use a 20 Vp-p setting on a 100 percent through-wall axial notc't The primary and secondary eddy current analysis teams were subsequently instructed (by a document entitled "ANO-2 Calibration Standard As-Built Dimensions") to set up voltage at 7.0 volts on a 60 percent through-wall inside diameter notch if the readings on the 100 percent through-wall axial notch were saturated.

This is a Severity Level IV violation (Supplement l} (50-368/9812-03).

Pursuant to the provisions of 10 CFR 2.201, Entergy Operations, Inc. is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV,611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a

" Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or sevarity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately ade resses the required response. If an adequate reply is ris received within the time specified l in tais Notice, an Order or a Demand for Information may be issued as to why the license should not ce modified, suspended, or revoked, or why such other action as may be proper should not )

be taken. Where good cause is shown, consideration will be given to extending the response time.

l if you contest this enforcement action, you should also provide a copy of your resporse to the l Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC l 20555-0001.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent i possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your I response that deletes such information. If you request withholding of such material, you must

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specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by

~ 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Arlington, Texas this 2nd day of April 1998

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