IR 05000313/2023003

Revised - ANO Revised Integrated Inspection Report 05000313/2023003 and 05000368/2023003 and Independent Spent Fuel Storage Installation Inspection Report 07200013/ 2023001

ML23324A212
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/21/2023
From:	John Dixon NRC/RGN-IV/DORS/PBD
To:	Pehrson D Entergy Operations
References
IR 2023003
Download: ML23324A212 (39)

Text

November 21, 2023

SUBJECT:

ARKANSAS NUCLEAR ONE - REVISED INTEGRATED INSPECTION REPORT 05000313/2023003 AND 05000368/2023003 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION INSPECTION REPORT 07200013/2023001

Dear Doug Pehrson:

On September 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Arkansas Nuclear One. The results of this inspection were originally issued in a report, dated November 13, 2023 (Agencywide Document Access and Management Systems (ADAMS) Accession No. (ML23313A096).

The NRC staff subsequently determined that the Performance Assessment section of the Green, non-cited violation (NCV)05000313/2023003-02, Failure to Maintain FLEX Equipment Consistent with the Requirements of 10 CFR 50.155(c)(1) was not included in the report. This error was due to an administrative oversight. Consistent with NRC processes, the Performance Assessment section has been added and this report is being reissued in whole.

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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, John L. Dixon, Jr., Chief Reactor Projects Branch D Division of Operating Reactor Safety Signed by Dixon, John on 11/21/23 Docket Nos. 05000313, 05000368, 07200013 License Nos. DPR-51, NPF-6

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000313, 05000368, and 07200013

License Numbers: DPR-51 and NPF-6

Report Numbers: 05000313/2023003, 05000368/2023003, and 07200013/2023001

Enterprise Identifier: I-2023-003-0007 and I-2023-001-0015

Licensee: Entergy Operations, Inc.

Facility: Arkansas Nuclear One

Location: Russellville, AR

Inspection Dates: July 1, 2023, to September 30, 2023

Inspectors: L. Brookhart, Senior Spent Fuel Storage Inspector R. Bywater, Senior Resident Inspector T. DeBey, Resident Inspector T. Farina, Senior Operations Engineer J. Freeman, Spent Fuel Storage Inspector S. Hedger, Senior Emergency Preparedness Inspector R. Kopriva, Senior Project Engineer K. Murphy, Operations Engineer B. Tharakan, Technical Assistant R. Williams, Operations Engineer

Approved By: John L. Dixon, Jr., Chief Reactor Projects Branch D Division of Operating Reactor Safety

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Arkansas Nuclear One, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Failure to Maintain FLEX Equipment Consistent with the Requirements of 10 CFR 50.155(c)(1)

Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.2] - Field 71111.12 Systems NCV 05000313/2023003-02 Presence Open/Closed The inspectors identified a Green, non-cited violation of 10 CFR 50.155(c)(1), Mitigation of Beyond-Design-Basis Events, when the licensee failed to maintain equipment of sufficient capacity and capability to implement strategies to maintain and restore core cooling, containment, and spent fuel cooling capabilities following a beyond-design-basis external event. Specifically, the licensee failed to implement a fuel oil quality strategy for FLEX diesel-driven equipment, and consequently, FLEX diesel generator K12 failed a surveillance test.

Failure to Conduct Drills in Accordance with the Site Emergency Plan Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green [H.13] - 71114.05 Preparedness NCV 05000313,05000368/2023003-03 Consistent Open/Closed Process The inspectors identified a Green non-cited violation of 10 CFR 50.54(q)(2) associated with the licensees failure to follow their emergency plan. Specifically, the licensee failed to follow Arkansas Nuclear One Emergency Plan, revisions 46 and 47, section N.2.4, which requires annual radiological monitoring drills. The licensee failed to conduct correctly scoped radiological monitoring drills in 2021 and 2022 by not including sampling activities both onsite and offsite.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000313, Use and Acceptance of the 60854 Open 05000368/2023003-01 Holtec Canister with the CBS Variant Design Change

PLANT STATUS

Unit 1 began the inspection period at approximately 96 percent power because of elevated lake temperatures and having only two circulating water pumps available. Unit 1 operators raised power to 100 percent on July 8, 2023, when lake temperature allowed full power operation. On July 20, 2023, lake temperatures became elevated again and Unit 1 operators began to reduce power. Power was stabilized at approximately 95.5 percent. Unit 1 operators restored the unit to full power on July 22, 2023, when lake temperature allowed full power operation. Unit 1 remained at or near full power for the remainder of the inspection period.

Unit 2 began the inspection period at full power. On September 10, 2023, Unit 2 operators detected a small (approximately 0.2 percent), unexpected, reduced power with simultaneous reduction in reactor coolant system cold leg A temperature, steam generator A pressure, and slight change in core flux azimuthal tilt. The licensee determined that core mass flow was less than required by technical specification 3.2.5 and Unit 2 operators reduced power to approximately 85 percent to restore compliance with the technical specification. The licensee concluded the most likely cause of the reduction in reactor coolant system flow was movement of the cold leg A safety injection system thermal sleeve. The licensee completed an analysis of the condition that allowed returning the unit to 100 percent power. Unit 2 operators raised power to 100 percent power on September 22, 2023, and the unit remained at or near full power for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 1 emergency diesel generator (K-4B) during outage of alternate train (K-4A)emergency diesel generator on August 1, 2023

(2) Unit 1 underground storage/fuel transfer system for emergency diesel generators after system outage and fuel transfer test on August 3, 2023

(3) Unit 1 125 Vdc vital dc power after charger problem/tripped breaker/degraded batteries on August 10, 2023

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Unit 1 intake structure FZ-1030, 1061, and 1062 on July 6, 2023

(2) Unit 1 computer room FZ-160-B on July 7, 2023

(3) Unit 2 main steam isolation valve/steampipe room FZ-2155-A on July 11, 2023

(4) Unit 2 north electrical equipment room FZ-2091-BB on July 12, 2023

(5) Unit 1 boric acid tank and pump room FZ-120-E on August 1, 2023

(6) Unit 1 north emergency diesel generator room FZ-86-G on August 31, 2023

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (2 Samples)

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered on June 7, 2023, to July 21, 2023.

(2) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered from June 19, 2023, to July 28, 2023.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)

(1) Biennial Requalification Written Examinations

The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on July 7, 2023.

Annual Requalification Operating Tests

The inspectors evaluated the adequacy of the licensees annual requalification operating test.

Administration of an Annual Requalification Operating Test

The inspectors evaluated the effectiveness of the licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the licensee is effectively evaluating their licensed operators for mastery of training objectives.

Requalification Examination Security

The inspectors evaluated the ability of the licensee to safeguard examination material, such that the examination is not compromised.

Remedial Training and Re-examinations

The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.

Operator License Conditions

The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.

Control Room Simulator

The inspectors evaluated the adequacy of the licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.

Problem Identification and Resolution

The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)

(1) The inspectors observed and evaluated licensed operator performance in the control room during Unit 2 crew response to degraded reactor coolant system flow and emergent power reduction on September 10, 2023.

(2) The inspectors observed and evaluated licensed operator performance in the control room during Unit 1 planned downpower to 86 percent and performance of main turbine governor valve testing on September 28, 2023.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (3 Samples)

(1) The inspectors observed and evaluated Unit 1 requalification job performance measure tasks (transfer control rods to auxiliary power supply, restore power to dead bus) on July 20, 2023.

(2) The inspectors observed and evaluated Unit 1 training scenario for pressurizer system failure events on August 15, 2023.

(3) The inspectors observed and evaluated Unit 2 training scenario for overcooling events and excess steam demand on August 22, 2023.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (4 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:

(1) maintenance due to non-functionality of Unit 2 area radiation monitor 2RITS-8905 for equipment hatch area (EITER equipment) on July 27, 2023

(2) Limitorque operator periodic inspection and lubrication on August 15, 2023

(3) manhole MH-8 mechanical inspection and dewatering on August 17, 2023

(4) FLEX diesel generator preventive maintenance practices following failure of the K12 diesel generator on November 10, 2021

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Unit 1 elevated risk from planned system maintenance on emergency diesel generator B on July 18, 2023

(2) Unit 2 elevated risk from planned system maintenance on atmospheric dump valve 2CV-0305 at power on July 20, 2023

(3) Unit 2 elevated risk from planned system maintenance on emergency diesel generator B on July 24, 2023

(4) Unit 1 elevated risk from planned system maintenance on emergency diesel generator A on August 2, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) operability of Unit 1 emergency feedwater initiation and control system pressure transmitter PT-2667A, installed with a low-pressure vent configuration, unlike the other pressure transmitters in the system, on July 24, 2023

(2) operability of Unit 1 emergency diesel generator 2 after 2-year overhaul on July 27, 2023

(3) operability of Unit 1 primary makeup pump B, P-36B, due to inboard seal leakage on August 30, 2023

(4) operability of Unit 2 reactor coolant system from a step change in reactor coolant flow in loop A due to a rotated or partially ejected high pressure injection thermal sleeve on September 10, 2023

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (PMT) (IP Section 03.01) (6 Samples)

(1) Unit 1 reactor protection system D control rod drive breaker trip test following maintenance on August 15, 2023

(2) Unit 1 emergency diesel generator K-4A testing following the 24-month maintenance and air valve replacements on August 17, 2023

(3) Unit 2 electrohydraulic pump following replacement on September 6, 2023

(4) Unit 1 vital battery charger D-03A following preventive maintenance on September 18, 2023

(5) Unit 1 emergency feedwater pump turbine steam generator A admission valve CV-2667 following major preventive maintenance on September 19, 2023

(6) Unit 1 emergency feedwater pump steam admission valve CV-2663 following major preventive maintenance on September 19, 2023

Surveillance Testing (IP Section 03.01) (4 Samples)

(1) Unit 2 emergency diesel generator 2K-4B fast start testing on August 24, 2023

(2) Unit 2 reactor building spray pump P-35B periodic test on September 12, 2023

(3) emergency cooling pond sounding on September 13, 2023

(4) Unit 2 Red train emergency feedwater suction valves on September 22, 2023

Inservice Testing (IST) (IP Section 03.01) (1 Sample)

(1) Unit 1 service water pump P-4B inservice test on August 8, 2023

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.01-02.04) (1 Sample)

(1) The inspectors evaluated the maintenance and testing of the alert and notification system between August 31, 2020, and August 19, 2023.

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.01-02.02) (1 Sample)

(1) The inspectors evaluated the readiness of the Emergency Preparedness Organization between August 31, 2020, and August 19, 2023. Inspectors also evaluated the licensee's ability to staff their emergency response facilities in accordance with emergency plan commitments.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes:

• Procedure 1903.010, Emergency Action Level Classification, revision 61, with change summary submitted on March 2, 2023

• Arkansas Nuclear One Emergency Plan, revision 48, with change summary submitted on May 11, 2023

In addition, the inspectors evaluated the 10 CFR 50.54(q) emergency plan change process and practices between August 30, 2020, and August 19, 2023. The evaluation reviewed screenings and evaluations documenting implementation of the process. The reviews of the change process documentation or the emergency plan changes do not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness

Inspection Review (IP Section 02.01 - 02.11) (1 Sample)

(1) The inspectors evaluated the maintenance of the emergency preparedness program between August 30, 2020, and August 19, 2023. The evaluation reviewed evidence of completing various emergency plan commitments, the conduct of drills and exercises, licensee audits and assessments, and the maintenance of equipment important to emergency preparedness. In addition, the inspectors observed an alternate emergency response facilities tabletop drill conducted on August 29, 2023.

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) emergency drill involving Unit 2 loss of coolant accident with fuel failure leading to a General Emergency declaration on September 26,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS06: Emergency AC Power Systems (IP Section 02.05)===

(1) Unit 1 (July 1, 2022, through June 30, 2023)

(2) Unit 2 (July 1, 2022, through June 30, 2023)

MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)

(1) Unit 1 (July 1, 2022, through June 30, 2023)

(2) Unit 2 (July 1, 2022, through June 30, 2023)

MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)

(1) Unit 1 (July 1, 2022, through June 30, 2023)

(2) Unit 2 (July 1, 2022, through June 30, 2023)

EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)

(1) July 1, 2022, through June 30, 2023

EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)

(1) July 1, 2022, through June 30, 2023

EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)

(1) July 1, 2022, through June 30, 2023

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

(1) Site challenges to maintaining radiation monitors and repeat instrument failures/obsolescence on August 17, 2023.

The sites corrective action program records and deficiency tagging of radiation monitors shows that keeping the instruments functional is an ongoing struggle. The instruments are obsolete, and it is increasingly difficult to maintain a supply of spare or replacement parts. Repaired instruments do not always continue to operate for a reasonable time and the time burden to site technicians is considerable. The sites plan to address this issue is still years from being implemented.

71153 - Follow Up of Events and Notices of Enforcement Discretion Personnel Performance (IP section 03.03)

(1) The inspectors evaluated the Unit 2 unplanned downpower to 85 percent for inadequate reactor coolant system flow on September 10,

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

===60854 - Preoperational Testing of an ISFSI

Determine by direct observation and independent evaluation whether the licensee had developed, implemented, and evaluated preoperational testing activities to safely load spent fuel from site's spent fuel pool to the Independent Spent Fuel Storage Installation (ISFSI) and safely retrieve spent fuel from the ISFSI and transfer it back to the licensee's spent fuel pool.

Preoperational Testing Of An ISFSI===

(1) Arkansas Nuclear One (ANO) is a 10 CFR Part 72 general licensee in accordance with 10 CFR 72.210. Previously, the ANO ISFSI consisted of two different cask designs. ANO had loaded 24 canisters of the Energy Solutions ventilated storage cask (VSC) design, VSC-24, (Certificate of Compliance (CoC) No. 72-1007) from 1996 to 2003. Then in 2003, ANO switched to loading the Holtec HI-STORM 100S version C overpacks (CoC 72-1014) containing either a multi-purpose canister (MPC)-24 or MPC-32 containing either 24 or 32 spent fuel assemblies. In 2023, ANO had elected to use the Holtec HI-STORM Flood/Wind (FW) system (CoC 72-1032) to continue storing fuel at the ISFSI. The site's ISFSI pads contained a total of 24 VSC-24 casks, 80 HI-STORM 100 casks and the future casks would be HI-STORM FW casks containing 37 spent fuel assemblies (MPC-37). On August 21-25, 2023, inspectors performed onsite inspections to observe and evaluate the pre-operational testing and training exercises being conducted by the licensee. These operations are described in condition 9 of the CoC and are performed by a general licensee prior to the use of the system to store spent fuel assemblies.

During the inspection period, inspectors specifically observed the following demonstrations that were successfully completed by the licensee:

• movement of the transfer cask from the fuel building to the Cask Transfer Facility using the low profile transporter and rail car

• transition of the transfer cask from the low profile transporter to the Vertical Cask Transporter (VCT)

• stack-up of the transfer cask on to the top of the FW overpack using the VCT

• download of the MPC simulator from the transfer cask into the FW overpack

• removal of the empty transfer cask from the stack-up position.

INSPECTION RESULTS

Unresolved Item Use and Acceptance of the Holtec Canister with the CBS 60854 (Open) Variant Design Change URI 05000313,05000368/2023003-01

Description:

The inspectors identified an unresolved item (URI) related to design changes on the dry cask storage multi-purpose canisters (MPC) utilized by the licensee. On November 6, 2020, Holtec International, the supplier of HI-STORM FW storage system, performed Engineering Change Order (ECO) No. 5018-122 and 72.48 Design No. 1498.

These evaluations performed a design change to introduce a new MPC basket design to the HI-STORM FW dry storage system, designated as the continuous basket shim (CBS) variant.

On September 12, 2023, the NRC issued Inspection Report 07201014/2022-201 (ADAMS Accession No. ML23145A175) to Holtec International, identifying three apparent violations associated with design change. The apparent violations, related to 10 CFR 72.48 and 10 CFR 72.146 requirements, are for Holtecs apparent failures to provide adequate bases that the CBS variant did not require a license amendment, failure to ensure the change did not result in a departure from the method of evaluations described in the Final Safety Analysis Report, and failure to establish design control measures commensurate with those applied to the original design. At this time, the NRC has determined there is no immediate safety concern associated with the use of the modified basket design.

On January 25, 2023, the licensee adopted Holtecs CBS ECO/72.48 through the licensees 72.48 program, LBDCR No. 2022-034, and subsequently loaded the MPC-37-CBS canister during their September 2023 loading campaign.

General licensees are responsible to ensure that each cask they use conforms to the terms, conditions, and specifications of a Certificate of Compliance (CoC) or an amended CoC listed in 72.214 and regulatory requirements in 10 CFR Part 72. Accordingly, pending determination of the final enforcement action to Holtec International associated with the design change, it may be determined that ANO's loading of the dry storage systems did not meet regulatory requirements.

Planned Closure Actions: The licensees performance related to the adoption and use of the MPC-37-CBS canister is unresolved at this time as the NRC has not made a final determination for the apparent violations documented in Inspection Report 07201014/2022-201. The inspectors can evaluate the general licensees compliance with regulatory requirements associated with loading of MPC baskets with the CBS variant once a final determination is made.

Licensee Actions: The licensee entered the issue into its corrective action program and initiated actions to review the results of the NRC's final determination and determine if changes are needed.

Corrective Action References: Condition Report CR-HQN-2023-03197

Failure to Maintain FLEX Equipment Consistent with the Requirements of 10 CFR 50.155(c)(1)

Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.2] - Field 71111.12 Systems NCV 05000313/2023003-02 Presence Open/Closed The inspectors identified a Green, non-cited violation of 10 CFR 50.155(c)(1), Mitigation of Beyond-Design-Basis Events, when the licensee failed to maintain equipment of sufficient capacity and capability to implement strategies to maintain and restore core cooling, containment, and spent fuel cooling capabilities following a beyond-design-basis external event. Specifically, the licensee failed to implement a fuel oil quality strategy for FLEX diesel-driven equipment, and consequently, FLEX diesel generator K12 failed a surveillance test.

Description:

The site employs various diesel-driven equipment for their Phase 2 FLEX strategies. To maintain adequate quality of the diesel engine fuel oil, annual fluid analysis was required to be completed by Section 5.3.3, FLEX Equipment Maintenance, of Procedure EN-OP-201-01, Arkansas Nuclear One FLEX Program Document, revision 4.

FLEX diesel fuel oil analysis for three parameters (kinematic viscosity, water and sediment, and cloud point) was required by Procedure OP-1000.113, Diesel Fuel Monitoring Program, revision 17. A Model Work Order was developed to perform the periodic sampling and analyses on a 1-year frequency and work orders were issued annually to perform the sampling. The inspectors found that FLEX fuel oil sampling was not being performed.

Instead, the completed work orders stated that fuel oil was replaced in lieu of sampling. No documentation of fuel oil replacement could be found. The documentation that was available indicated the FLEX equipment diesel tanks were initially filled in the 2015-timeframe; and, tanks had not been inspected for water or sediment, fuel oil had not been sampled and analyzed, and tanks had not been drained and refilled with fresh fuel oil.

On November 10, 2021, the K12 800 kW FLEX diesel generator failed its 3-year full load surveillance test and was not capable of fulfilling its mission to power critical loads during a beyond-design-basis event. The licensees equipment failure evaluation (CR-ANO-C-2021-02976 CA-03) documented discovery that every O-ring, seal, washer, and gasket needed reseal, for one of the two fuel oil injection pumps. Debris from the failed fuel oil injection pump clogged the fuel injectors on one side of the engine, preventing its operation at full load.

The evaluation did not document a cause for the failed injection pump (and the inspectors did not find any documentation of cause in the corrective maintenance work order), but it documented that the vendor manual contained a recommendation that inspection, testing, and replacing parts as necessary for the fuel oil injection pump be performed every 4 years.

The licensee had not included this recommendation in the FLEX diesel generator preventive maintenance program. In addition to replacing the fuel oil injection pumps on both the K12 and K11 diesel generators, a corrective action was initiated to add the 4-year, vendor-recommended, fuel oil injection pump preventive maintenance to the preventive maintenance program. Based on the facts that FLEX fuel oil sampling and analysis had not been performed and fuel oil in FLEX equipment was not being periodically replaced, and that diesel fuel oil is expected to degrade over time, the inspectors concluded degraded fuel oil contributed to the failure.

The inspectors reviewed the licensees FLEX diesel generator preventive maintenance requirements with those recommended in the K11/K12 Vendor Manual TDG971 0010, FLEX Portable Diesel Generator, revision 0. Procedure EN-OP-201-01, Arkansas Nuclear One FLEX Program Document, revision 4, identified the following preventive maintenance items and frequencies for the K11/K12 FLEX diesel generators:

Functional Test and Inspection 6 months Operational Inspection, Fluid Analysis 1 year Fluid Filter Replacement 2 years Generator Full Load Test 3 years

The vendor manual identified several additional preventive maintenance recommendations and some that were at different frequencies for engines used as emergency engines.

Examples of vendor-recommended preventive maintenance activities that the licensee did not include were: operate the engine weekly at no load; operate the engine monthly at 1/2 load; drain water out of the fuel tank annually; drain water from fuel filters annually; and check fuel injector spray conditions and spray pressure annually.

The licensee believes that technical justifications for deviations from vendor recommendations for preventive maintenance were not required because their FLEX preventive maintenance program implemented the EPRI Templates referenced in Nuclear Energy Institute (NEI) letter dated October 3, 2013, which forwarded EPRI Technical Report 3002000623, Nuclear Maintenance Applications Center: Preventive Maintenance Basis for FLEX Equipment, (ADAMS Accession No. ML13276A573). This was endorsed by the NRC in a letter dated October 7, 2013, (ADAMS Accession No. ML13276A224). The EPRI document described the expansion of EPRIs preventive maintenance basis database to include FLEX equipment and a process for developing preventive maintenance templates for FLEX equipment. The licensee informed the inspectors that the preventive maintenance program for their K11 and K12 FLEX diesel generators (which have Mitsubishi engines) were based on the EPRI template created for FLEX generators (which was based on John Deere engines). The licensee stated that similar expectations exist for normal-use periodic operating requirements for John Deere and Mitsubishi engines, so it was appropriate to use the EPRI templates for the ANO FLEX diesel generators. The licensees position was that they follow the EPRI templates and evaluate any deviations from them; evaluations were not required for deviations from vendor recommendations.

The inspectors reviewed the licensees FLEX preventive maintenance template (based on the EPRI template) for the FLEX Diesel Generators, PM Basis Template EN FLEX Generator -

1000KW or Less - Diesel Driven, revision 0. The inspectors found the licensee had identified and evaluated one deviation from the EPRI template. The licensees PM Basis template said the EPRI template identified a 3-month frequency for the FLEX diesel generator Functional Test and Inspection. However, the licensee stated a 6-month frequency was acceptable because their use of an EPRI PM Database Vulnerability Tool resulted in only a 2 percent increase in failure rate for the extended frequency. The inspectors noted that the licensees FLEX preventive maintenance template also included a note stating, This template is intended to be used in consultation with the specific vendor manuals associated with the specific equipment of interest. Neither the deviation from the template, nor any other location in the template, referenced recommendations from the Mitsubishi vendor manual.

The NRCs October 7, 2013, letter (issued after NRC endorsement of NEI 12-06, revision 0)regarding EPRI templates, only stated that the staff agreed that the EPRI Report and templates provided a useful input to an acceptable approach for licensees to use in developing their maintenance and testing programs. The inspectors noted that NEI has issued revision 4 of NEI 12-06 (ADAMS Accession No. ML16354B421) and it was reviewed and endorsed by the NRC when NRC issued JLD-ISG-2012-01, revision 2, in February 2018 (ADAMS Accession No. ML17005A188). This document, with an effective date of April 25, 2018, represented the most recent NRC guidance and clarification for meeting FLEX requirements. The inspectors reviewed NEI 12-06, revision 4, and noted an important clarification was added in section 11.5 for FLEX maintenance and testing that was not included in revision 0.

Revision 0:

Standard industry templates (e.g., EPRI) and associated bases will be developed to define specific maintenance and testing including the following:

Revision 4:

Standard industry templates (e.g., EPRI) and associated bases (i.e., site-specific)

[emphasis added] will be developed to define specific maintenance and testing including the following:

The text immediately following was the same in both revisions, including statements for periodic testing and frequency and preventive maintenance, that, The basis should be documented and deviations from vendor recommendations and applicable standards should be justified.

The inspectors concluded the addition of site-specific in the language of NEI 12-06, revision 4, provided added emphasis on the need for the licensee to evaluate differences between the generic EPRI templates and site-specific equipment requirements that are needed for different equipment, like Mitsubishi diesel generators.

Corrective Actions: The licensee was not able to repair the K12 engine on site. It was transported to a vendor site in Louisiana where the engine was repaired and returned to the ANO site. The ANO Flex Marshal position was transitioned to a different employee and diesel fuel sampling of the FLEX equipment was initiated in 2023 at a quarterly periodicity until fuel quality was definitively documented and trended.

Corrective Action References: The licensee entered this issue into the sites corrective action program with condition reports CR-ANO-C-2023-03536 and CR-ANO-C-2023-03537.

Performance Assessment:

Performance Deficiency: The failure to maintain equipment reliability for mitigation strategies for beyond-design basis external events was a performance deficiency. Specifically, the licensee failed to perform fuel oil sampling and analysis to maintain fuel oil quality for FLEX diesel-driven equipment which contributed to the failure of FLEX diesel generator K12.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to implement a fuel oil quality strategy for FLEX diesel-driven equipment, and consequently, FLEX diesel generator K12 failed a surveillance test and was not functional for almost 3 months.

Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using the Mitigating Systems exhibit 2, section E, for FLEX findings, the inspectors determined that the issue finding screened as Green because:

1. it was not associated with equipment, training, procedures, and/or other programmatic aspects credited for the sole purpose of satisfying the requirements of Order EA-12-051 or 10 CFR 50.155 for spent fuel pool instrumentation or EA-13-109 for containment venting; and,

2. it did not involve equipment, training, procedures, and/or other programmatic aspects credited in any Phase 1 or 2 FLEX strategy such that any FLEX function (such as extended high-pressure coolant injection/reactor core isolation cooling/auxiliary feedwater operation, providing FLEX dc power, FLEX ac power, or FLEX reactor coolant system feed) could not be completed in accordance with existing plant procedures within the time allotted for an exposure period of greater than 21 days.

Specifically, the licensee failed to implement a fuel oil quality strategy for FLEX diesel-driven equipment, where the licensee failed to perform fuel oil analysis at the specified annual frequency, and consequently, FLEX diesel generator K12 failed testing and was unavailable for almost 3 months. However, the FLEX ac power function could have been completed because the backup piece of equipment (the K11 FLEX portable diesel generator) remained available and could have been used within the time allotted.

Cross-Cutting Aspect: H.2 - Field Presence: Leaders are commonly seen in the work areas of the plant observing, coaching, and reinforcing standards and expectations. Deviations from standards and expectations are corrected promptly. Senior managers ensure supervisory and management oversight of work activities, including contractors and supplemental personnel.

Specifically, although the FLEX program was an Entergy fleet program, the ANO operations department was responsible for implementing the FLEX equipment testing and maintenance at the ANO site. Inadequate training was given to the ANO FLEX Marshal and little, if any, direct supervisory oversight occurred.

Enforcement:

Violation: NRC regulation 10 CFR 50.155(c)(1) states, The equipment relied on for the mitigation strategies and guidelines required by paragraph (b)(1) of this section must have sufficient capacity and capability to perform the functions required by paragraph (b)(1) of this section. Paragraph (b)(1) states, in part, that strategies and guidelines must include the following:

(i) Maintaining or restoring core cooling, containment, and spent fuel pool cooling capabilities

The licensee describes its strategies to meet 10 CFR 50.155(b)(1) and (c)(1) in Procedure EN-OP-201-01, Arkansas Nuclear One FLEX Program Document, revision 4, which required annual analysis of FLEX fuel in accordance with Procedure OP-1000.113, Diesel Fuel Monitoring Program, revision 17.

Contrary to the above, since 2015, the licensee failed to implement the annual sampling and analysis requirements for FLEX diesel fuel in accordance with procedures EN-OP-201-01 and OP-1000.113.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

Failure to Conduct Drills in Accordance with the Site Emergency Plan Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green [H.13] - 71114.05 Preparedness NCV 05000313,05000368/2023003-03 Consistent Open/Closed Process The inspectors identified a Green, non-cited violation of 10 CFR 50.54(q)(2) associated with the licensees failure to follow their emergency plan. Specifically, the licensee failed to follow Arkansas Nuclear One Emergency Plan, revisions 46 and 47, section N.2.4, which requires annual radiological monitoring drills. The licensee failed to conduct correctly scoped radiological monitoring drills in 2021 and 2022 by not including sampling activities both onsite and offsite.

Description:

The inspectors reviewed drills and exercises conducted by the licensee between 2020 and 2022 and compared the drill and exercise evaluation reports to the requirements of the licensee emergency plan.

Arkansas Nuclear One Emergency Plan, revisions 46 and 47, section N.2.4, requires that plant environs and radiological monitoring drills (on and offsite) are conducted annually. To verify these took place, the inspectors evaluated radiological monitoring drill reports (environmental drills) held on August 6, 2020, June 3, 2021, and June 1, 2022. In reviewing the reports, the inspectors observed that the sampling locations were denoted with alpha-numeric codes, so further questions were asked about where they were located with respect to the site boundary. Discussion with the licensee staff revealed that sampling activities in 2020 took place appropriately both onsite and offsite, but in 2021 and 2022 the samples were only evaluated at offsite locations.

The inspectors reviewed the licensees documentation describing how emergency preparedness drills were developed and implemented. To ensure that the drill included necessary aspects of scope in design, the licensee modified Performance Objective I.9, Environmental Phase Monitoring, taken from Procedure EN-EP-306, Drills and Exercises, attachment 6, to include more specific language. It was revised to say, Demonstrate the ability to monitor post-plume environmental conditions in the field (at least one sample onsite and one offsite). This performance objective was used effectively in 2020 to ensure that the drill scope included sampling activities onsite and offsite, as well as to conduct the drill correctly. In 2021, the radiological monitoring drill used the same performance objective in design, but the licensee failed to use it to ensure appropriate implementation. In 2022, after some changes to drill documentation format, the performance objective statement was revised, removing text reinforcing the need for onsite and offsite sampling, introducing an error in drill design.

The inspectors determined that the licensee did not conduct annual radiological monitoring drills in a manner that ensured that all sampling activities were evaluated in all specified locations. Therefore, the inspectors concluded that the licensee did not follow the requirements of the site emergency plan.

Corrective Actions: The licensee entered these issues into the corrective action program.

Corrective Action References: Condition Report CR-ANO-C-2023-03166

Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to conduct drills required by the emergency plan is a performance deficiency within the licensees ability to foresee and correct.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the ERO Performance attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The licensees ability to take adequate measures to protect the health and safety of the public is degraded when the licensee does not perform drills and exercises to ensure emergency response organization proficiency.

Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix B, Emergency Preparedness SDP. Using attachment 2, the performance deficiency was determined to have very low safety significance (Green) because it was a failure to comply with NRC requirements, was not a loss of planning standard function, and was not a degraded risk significant planning standard function. The planning standard function was not lost because the licensee did conduct drills, training, and normal sampling activities that addressed portions of the related emergency plan commitments.

Cross-Cutting Aspect: H.13 - Consistent Process: Individuals use a consistent, systematic approach to make decisions. The licensee did not use a consistent, systematic approach to making decisions regarding use of radiological monitoring drills performance objectives.

Specifically, the associated drill performance objectives were not used regularly to ensure that drills as implemented included the appropriate scope elements in the evaluation. This would have provided assurance that the emergency plan commitments would be addressed in a regular fashion.

Enforcement:

Violation: Title 10 CFR 50.54(q)(2) requires, in part, that a power reactor licensee follow an emergency plan which meets the requirements of appendix E to 10 CFR Part 50 and the standards of 10 CFR 50.47(b). Planning standard 10 CFR 50.47(b)(14) requires, in part, that the licensee conduct periodic drills to maintain key skills. Arkansas Nuclear One Emergency Plan, revisions 46 and 47, section N.2.4, states, in part, that plant environs and radiological monitoring drills (on and offsite) are conducted annually.

Contrary to the above, between January 1, 2022, and September 1, 2023, Arkansas Nuclear One failed to follow an emergency plan which met the requirements of appendix E and the standards of 10 CFR 50.47(b). Specifically, the licensee failed to conduct annual radiological monitoring drills including sampling activity evaluation both on and offsite in 2021 and 2022, which are required by the emergency plan to maintain key emergency response organization skills.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

• On July 13, 2023, the inspectors presented the ANO-1 2023 biennial requalification inspection results to Albert Fields, Training Supervisor, and other members of the licensee staff.

• On September 1, 2023, the inspectors presented the emergency preparedness program inspection results to Frank Shewmake, Operations Director, and other members of the licensee staff.

• On October 19, 2023, the inspectors presented the ANO independent spent fuel storage installation dry run operations inspection results to Brian Patrick, Regulatory Assurance and Performance Improvement Director, and other members of the licensee staff.

• On October 19, 2023, the inspectors presented the integrated inspection results to Brian Patrick, Regulatory Assurance and Performance Improvement Director, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

60854 Corrective Action CR-HQN-2023-03197 Holtec MPC-CBS Variant 0

Documents

60854 Procedures Procedure 3407.003 HI-STORM FW Loading Operations 0

60854 Procedures Procedure 3407.005 HI-STORM FW Transfer and Transport Operations 0

71111.04 Corrective Action CR-ANO-1-2022-00794, 1-2022-00883, 1-2023-00164, 1-2023-

Documents 00453, 1-2023-00492, 1-2023-00499, 1-2023-00790, 1-

23-00791, 1-2023-01339, C-2022-003531, C-2023-

2882

71111.04 Procedures OP-1104.036 Emergency Diesel Generator Operation 90

71111.04 Procedures OP-1412.081 Battery Chargers Cleaning and Inspection 22

71111.04 Procedures OP-1412.216 Vital 120 VAC 10 KVA Inverter Inspection 0

71111.04 Procedures ULD-1-SYS-03 Unit 1 125 Volt DC System 9

71111.04 Work Orders WO 52976861

71111.05 Corrective Action CR-ANO-1-2022-01281, 1-2022-01651, 1-2022-03111, 1-2023-

Documents 00794, 1-2023-01915, C-2021-00858, C-2023-01341,

71111.05 Engineering EC-94147 EC Reply to Point to Documentation Stating Fire Wrap is

Changes not Required in Correlation with EC-85804

71111.05 Miscellaneous FHA Unit 1 and Unit 2 Fire Hazards Analysis 11

71111.05 Miscellaneous PFP-U1-R021 Unit 1 Prefire Plans 21

71111.05 Miscellaneous PFP-U2-R17 Unit 2 Prefire Plans 17

71111.05 Procedures OP-1003.005 Fire Prevention Inspection 22

71111.05 Procedures PFP-U1 ANO Prefire Plan (Unit 1) 22

71111.05 Procedures PFP-U2 ANO Prefire Plan (Unit 2) 18

71111.11B Corrective Action CR-ANO-1-2021-Condition Report (Exam Security) 08/10/2021

Documents 02574

71111.11B Corrective Action CR-ANO-1-2022-NI Calibration PU&A 03/23/2022

Documents 00513

71111.11B Corrective Action CR-ANO-1-2023-Operations Training Staffing 06/15/2023

Documents 00857

71111.11B Corrective Action CR-ANO-C-2021-Exam Security 09/27/2021

Documents 02533

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.11B Corrective Action CR-ANO-C-2022-Condition Report (Exam Security) 02/11/2022

Documents 00407

71111.11B Corrective Action CR-ANO-C-2022-Condition Report (Exam Security) 05/05/2022

Documents 01251

71111.11B Corrective Action CR-ANO-C-2022-Operator Qualification Requirements 07/11/2022

Documents 01881

71111.11B Corrective Action CR-ANO-C-2023-Condition Report (Exam Security) 01/31/2023

Documents 00294

71111.11B Corrective Action CR-ANO-C-2023-NRC Medical Reporting 05/09/2023

Documents 01375

71111.11B Corrective Action DR-21-0051 Simulator Discrepancy Report 09/02/2021

Documents

71111.11B Corrective Action DR-22-0034 Simulator Discrepancy Report 11/17/2022

Documents

71111.11B Corrective Action DR-23-0011 Simulator Discrepancy Report 04/20/2023

Documents

71111.11B Corrective Action EN-FAP-OM-029 Rev Maintaining Condenser Vacuum while P-3B and P-3D 06/01/2023,

Documents 5 Adverse Condition are OOS Rev 2

Monitoring and

Contingency Plan

71111.11B Corrective Action EN-FAP-OM-029 Rev Elevated Main Generator Hydrogen Leakage 03/20/2023,

Documents 5 Adverse Condition Rev 5

Monitoring and

Contingency Plan

71111.11B Corrective Action EN-FAP-OM-029 Rev Elevated Exciter Air Cooler Temperatures 07/03/2023,

Documents 5 Adverse Condition Rev 0

Monitoring and

Contingency Plan

71111.11B Corrective Action TQF-201-IM05 Cycle 2201 Simulator Evaluation Remediation 09/07/2021,

Documents Rev 0

71111.11B Corrective Action WT-WTANO-2021-Operator Diagnosis - Plant Event 09/07/2021

Documents 00014

71111.11B Corrective Action WT-WTANO-2021-LOR Performance Issue - RB CLG Actions 09/13/2021

Documents 00270

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.11B Miscellaneous ANO1 Modifications Not Completed Last Two Years 06/09/2023

(none)

71111.11B Miscellaneous ANO1 Simulator Open Work Items 6-9-23 06/09/2023

71111.11B Miscellaneous JPM Overlap

71111.11B Miscellaneous ANO-1 Simulator Core Reload Acceptance Test - Cycle

71111.11B Miscellaneous Cycle 22 and 23 Training Attendance Records

71111.11B Miscellaneous 2023 Annual Operating Test - Week 2 0

71111.11B Miscellaneous 2023 Annual Operating Test - Week 4 0

71111.11B Miscellaneous A1JPM-RO-EDG10 Perform Starting the Emergency Diesel Without DC 17

Control Power

71111.11B Miscellaneous A1JPM-RO-NNI02 Reset NNI-Y Power Supply 1

71111.11B Miscellaneous A1REC-SIM-ANSI Unit 1 Cycle 31 Simulator Operability Test 0

71111.11B Miscellaneous A1WEXLORBIENNIAL RO Week 3 Written Examination 0

2305 RO Week 3

71111.11B Miscellaneous A1WEXLORBIENNIAL SRO Week 3 Written Examination 0

2305 SRO Week 3

71111.11B Miscellaneous eSOMS Report - Watchstanding Records Crew B 06/08/2023

Watchstanding

Records

71111.11B Miscellaneous Licensed Operator Six licensed operator medical records N/A

Medical Records

71111.11B Miscellaneous SES-1-016 ANO1 Dynamic Exam Scenario 5

71111.11B Miscellaneous SES-1-032 ANO1 Dynamic Exam Scenario 13

71111.11B Procedures 1063.008 Operations Training Sequence 50

71111.11B Procedures ASREC-OPS-FHSRO Activation of SRO License for Fuel Handling Activities50

71111.11B Procedures ASREC-OPS-LICRA Activation of RO License 50

71111.11B Procedures DG-TRNA-015-Simulator Exam Security Guidelines 25

EXAMSEC

71111.11B Procedures EN-OP-115-06 Activation and Deactivation of Licenses, and Maintaining 3

Active License Status

71111.11B Procedures EN-TQ-210 Conduct of Simulator Training 17

71111.11B Procedures EN-TQ-218 Licensed Operator Requalification Annual and Biennial 0

Exam Development

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.11B Procedures TQF-210-DD04 RO/SRO Performance Evaluation Report 4

71111.11B Procedures TQF-210-DD04-Grade RO/SRO Performance Evaluation Grading Criteria 2

71111.11Q Corrective Action CR-ANO-1-2019-01821, 1-2019-04374, 1-2021-01867, 2-2023-

Documents 02453, 2-2023-02457

71111.11Q Miscellaneous NPF-6 Appendix A, Technical Specifications to Facility 85

Operating License

71111.11Q Procedures AOP-2203.011 RCS Overcooling Technical Guidelines 7

71111.11Q Procedures AOP-2203.050 Overcooling Event in Modes 1 or 2 Technical Guidelines5

71111.11Q Procedures OP-1102.004 Power Operation 80

71111.11Q Procedures OP-1103.004 Soluble Poison Concentration Control 37

71111.11Q Procedures OP-1103.005 Pressurizer Operations 52

71111.11Q Procedures OP-1103.013 RCS Leak Detection 48

71111.11Q Procedures OP-1106.009 Turbine Startup 64

71111.11Q Procedures OP-1107.002 ES Electrical System Operation 51

71111.11Q Procedures OP-1203.015 Pressurizer Systems Failures 24

71111.11Q Procedures OP-2102.004 Power Operation 75

71111.11Q Procedures OP-2103.018 RCS Flow Rate Calculation 11

71111.11Q Procedures OP-2203.025 RCP Emergencies 21

71111.11Q Procedures OP-2203.050 Overcooling Event in Modes 1 or 2 5

71111.11Q Work Orders WO 53030817, 53030820

71111.12 Corrective Action CR-HQN-2020-00226, WT-WTANO-2022-00058, WT-

Documents WTANO-2022-00270

71111.12 Corrective Action CR-ANO-2-2022-01408, 2-2023-00108, 2-2023-00859, 2-2023-

Documents 01808, C-2021-02976, C-2021-02985, C-2022-00269,

C-2022-00376, C-2022-00538, C-2022-00890, C-2022-

225, C-2022-01388, C-2022-01397, C-2023-00036,

C-2023-00387, C-2023-03536, C-2023-03537,

71111.12 Miscellaneous PM Basis Template EN FLEX Generator - 1000KW or 11/21/2014

Less - Diesel Driven

71111.12 Miscellaneous 2016-00051 FLEX Oil PM Sampling Parameters & Acceptance 03/28/2016

Criteria Position Paper

71111.12 Miscellaneous EMRG36864 Operators Manual - 9.0 L OEM Diesel Engines 03/06/2013

71111.12 Miscellaneous IDLC8000-2M Generac Industrial Diesel Generator

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.12 Miscellaneous IPH1250/175DJ High Performance Industrial Pumping Module 11/2014

71111.12 Miscellaneous MWO 00298463-01 Manhole MH-8, Mechanical: Inspection and Dewatering 03/10/2022

71111.12 Miscellaneous TDG971 0010 FLEX Portable Diesel Generator 0

71111.12 Procedures CFSG-005 Initial Assessment and FLEX Equipment Staging 11

71111.12 Procedures EN-EP-202 Equipment Important to Emergency Response 4

71111.12 Procedures EN-MA-141 Limitorque Valve Operator Model SMB/SB/SBD-000 23

Through 5 MOV and HBC Periodic Inspection

71111.12 Procedures EN-OP-201 Diverse and Flexible Coping Strategies (FLEX) Fleet 5

Program Document

71111.12 Procedures EN-OP-201-01 Arkansas Nuclear One FLEX Program Document 4

71111.12 Procedures OP-1000.113 Diesel Fuel Monitoring Program 17

71111.12 Procedures OP-1903.010 Emergency Action Level Classification 61

71111.12 Procedures OP-2105.016 Radiation Monitoring and Evacuation System 34

71111.12 Procedures OP-2404.018 U2 Containment Area Rad Mon Sys Cal 5

71111.12 Work Orders WO 52929822, 52971630

71111.13 Corrective Action CR-ANO-2-2020-01970, 2-2020-03874, 2-2021-00251, 2-2022-

Documents 02139, C-2023-02904

71111.13 Procedures COPD-024 Risk Assessment Guidelines 75

71111.13 Procedures EN-WM-104 On Line Risk Assessment 27

71111.13 Procedures OP-1104.036 Emergency Diesel Generator Operation 90

71111.13 Procedures OP-1107.001 Electrical Systems Operations 135

71111.13 Procedures OP-2104.036 Emergency Diesel Generator Operations 104

71111.13 Procedures OP-2104.037 Alternate AC Generator Operations 38

71111.13 Procedures OP-2105.008 Steam Dump and Bypass Control System Operations 38

71111.13 Procedures OP-2107.001 Electrical Systems Operations 138

71111.13 Work Orders WO 52988793, 53012021

71111.15 Calculations CALC-07-R-1002-01 ECCS Leakage Quantities to the Auxiliary Building 1

71111.15 Calculations CALC-89-E-0039-02 HPI Seal Integrity Evaluation 1

71111.15 Corrective Action CR-ANO-1-2022-02669, 1-2022-02739, 1-2023-00378, 1-2023-

Documents 00896, 1-2023-01190, 2-2023-2457, 2-2018-2976, 2-

2013-1190

71111.15 Drawings M-2210, Sheet 1 Piping and Instrument Diagram Service Water System 93

71111.15 Engineering 0054051358 RCS Flow Margin Improvement 09/20/2023

Inspection Type Designation Description or Title Revision or

Procedure Date

Changes

71111.15 Engineering 529844 Unit 2 Service Water Loop 2 Suction Supply to 2P-7A 08/11/2023

Changes Leak

71111.15 Engineering 54036605 Operability Input Regarding CR-ANO-2-2023-02299 08/12/2023

Changes Service Water Leak Near Loop 2 Supply Header Drain

Valve 2SW-1551"

71111.15 Miscellaneous ASME Boiler and Evaluation Criteria for Temporary Acceptance of Flaws 05/07/2014

Pressure Vessel in Moderate Energy Class 2 or 3 Piping,Section XI,

Code, Code Case N-Division 1

513-4

71111.15 Miscellaneous STM 1-04 Primary Makeup and Purification 9

71111.15 Miscellaneous ULD-1-SYS-02 ANO-1 Makeup and Purification/High Pressure Injection 0

System

71111.15 NDE Reports Report No.: 2-BOP-Component ID: 2SW-1551, U2-327 Squeeze Pit. 08/12/2023

UT-23-024

71111.15 NDE Reports Report No.: 2-BOP-Component ID: A SI Nozzle Thermal Sleeve, A SI 03/27/2020

VE-20-001 Nozzle Thermal Sleeve Detection

71111.15 NDE Reports Report No.: 2-BOP-Component ID: C SI Nozzle Thermal Sleeve, C SI 03/27/2020

VE-20-002 Nozzle Thermal Sleeve Detection

71111.15 NDE Reports Report No.: 2-BOP-Component ID: D SI Nozzle Thermal Sleeve, D SI 03/27/2023

VE-20-003 Nozzle Thermal Sleeve Detection

71111.15 NDE Reports Report No.: 2-BOP-Component ID: C SI Nozzle Thermal Sleeve, C SI 04/21/2023

VE-20-003 Nozzle Thermal Sleeve Detection

71111.15 NDE Reports Report No.: 2-BOP-Component ID: D SI Nozzle Thermal Sleeve, D SI 04/21/2023

VE-20-004 Nozzle Thermal Sleeve Detection

71111.15 NDE Reports Report No.: 2-BOP-Component ID: B Safety Injection, B Safety 03/30/2020

VE-20-004 Inspection

71111.15 NDE Reports Report No.: 2-BOP-Component ID: A SI Nozzle Thermal Sleeve, A SI 09/29/2021

VE-21-001 Nozzle Thermal Sleeve Detection

71111.15 NDE Reports Report No.: 2-BOP-Component ID: D SI Nozzle Thermal Sleeve, D SI 10/08/2021

VE-21-005 Nozzle Thermal Sleeve Detection

71111.15 NDE Reports Report No.: 2-BOP-Component ID: A SI Nozzle Thermal Sleeve, A SI 04/21/2023

VE-23-002 Nozzle Thermal Sleeve Detection

71111.15 NDE Reports Report No.: 2-BOP-Component ID: 2HBC-86-6 Pipe, U2 335 North Hallway 08/11/2023

Inspection Type Designation Description or Title Revision or

Procedure Date

VE-23-008

71111.15 NDE Reports Report No.: 2-BOP-Component ID: 2SW-1551, U2-327 Squeeze Pit. 08/12/2023

VE-23-009

71111.15 Procedures EN-LI-102 Corrective Action Program 49

71111.15 Procedures EN-OP-104 Operability Determination Process 18

71111.15 Procedures OP-1104.036 Emergency Diesel Generator Operation 90

71111.15 Procedures OP-1304.098 Unit 1 EFIC Channel A Calibration 32

71111.15 Procedures OP-1304.135 Unit 1 Emergency Diesel Generator K-4B Instrument 24

Calibration

71111.15 Procedures OP-1305.003 M/U & Purification Sys. Integrity Test & Leak Rate 16

Determination

71111.15 Procedures Report No.: 2-BOP-Component ID: C SI Nozzle Thermal Sleeve, C SI 10/08/2021

VE-21-004 Nozzle Thermal Sleeve Detection

71111.15 Work Orders WO 52990667, 52997083

71111.24 Calculations CALC-91-E-0099-13 ECP Hydrographic Survey 0

71111.24 Corrective Action 1-2022-00883, 1-2022-02658, 2-2022-00423, 2-2022-

Documents 01383, 2-2023-01393, 2-2023-02352, 2-2023-02424, 2-

23-02439, C-2021-01589, C-2022-02560, C-2023-

289, C-2023-03344, 1-2023-1309, 1-2023-1310,

71111.24 Engineering EC-49838 2CV-1036-2 Control Wiring Modification

Changes

71111.24 Engineering EC-58310 2CV-0716-1 Acceptable Normal Range and Limiting

Changes Value Stroke Time Limits for Open Stroke Time to be

Used in OP-2106-006 Supplement 3A

71111.24 Engineering EC-90103 P-4B Service Water Acceptance Criteria Rebaseline per

Changes WO 540399

71111.24 Miscellaneous Unit 1 Station Log 08/03/2023

71111.24 Miscellaneous ANO Performance Indicator Report for 4Q22 01/18/2023

71111.24 Miscellaneous ULD-1-SYS-03 Unit 1 125 Volt DC System 9

71111.24 Miscellaneous ULD-2-SYS-12 ANO U2 Emergency Feedwater System 10

71111.24 Procedures EN-MA-141 Limitorque Valve Operator Model SMB/SB/SBD-000 23

Through 5 MOV and HBC Periodic Inspection

71111.24 Procedures OP-1104.005 Unit 2 Reactor Building Spray System Operation 92

71111.24 Procedures OP-1104.029 Service Water and Auxiliary Cooling System 127

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.24 Procedures OP-1104.036 Emergency Diesel Generator Operation 90

71111.24 Procedures OP-1107.004 Battery and 125 VDC Distribution 34

71111.24 Procedures OP-1304.128 Unit 1 RPS-D/CRD Breaker Trip Test 28

71111.24 Procedures OP-1306.019 Annual Emergency Cooling Pond Sounding 19

71111.24 Procedures OP-1402.066 24-month inspection of Unit One Emergency Diesel 42

Generator Engine

71111.24 Procedures OP-2104.036 Emergency Diesel Generator Operations 104

71111.24 Procedures OP-2104.037 Alternate AC Diesel Generator Operations 38

71111.24 Procedures OP-2106.006 Emergency Feedwater System Operations 110

71111.24 Procedures OP-2106.012 Electrohydraulic Oil System Operation 32

71111.24 Work Orders WO 569303, 52996055, 53004058, 53009255, 53029292,

53029670, 53036465, 53037178, 53037312, 54027672,

54033183, 54039748, 54048783, 52995597, 52996095,

53038477

71114.02 Corrective Action CR-ANO-C-2021-00978, C-2023-01794

Documents

71114.02 Miscellaneous Letter of Agreement Between Entergy Operations, Inc., 12/14/2022

and Radio Station KXRJ

71114.02 Miscellaneous KLD TR-1208 Arkansas Nuclear One Alert and Notification System 12/14/2020

(ANS) Design Report

71114.02 Procedures EP-002 ANO Emergency Planning Desk Guide - Early Warning 18

System

71114.03 Corrective Action CR-ANO-C-2023-01762, C-2023-01763

Documents

71114.03 Corrective Action CR-ANO-C-2023-03114

Documents

Resulting from

Inspection

71114.03 Miscellaneous Form 1903.062C Emergency Response Staffing Drill - March 10, 2022 03/28/2022

71114.03 Miscellaneous Form 1903.062C Emergency Response Staffing Drill - February 10, 202102/11/2021

71114.03 Miscellaneous Form 1903.062C Emergency Response Staffing Drill - June 25, 2022 06/28/2022

71114.03 Miscellaneous Form 1903.062C Emergency Response Staffing Drill - June 19, 2021 06/22/2021

71114.03 Miscellaneous Form 1903.062C Emergency Response Staffing Drill - September 21, 09/22/2022

22

Inspection Type Designation Description or Title Revision or

Procedure Date

71114.03 Miscellaneous Form 1903.062C Emergency Response Staffing Drill - September 23, 09/28/2021

21

71114.03 Miscellaneous Form 1903.062C Emergency Response Staffing Drill - December 4, 2020 12/10/2020

71114.03 Miscellaneous Form 1903.062C Emergency Response Staffing Drill - December 16, 2021 12/21/2021

71114.03 Miscellaneous Form 1903.062C Emergency Response Staffing Drill - March 21, 2023 03/21/2023

71114.03 Miscellaneous Form 1903.062C Emergency Response Staffing Drill - June 25, 2023 06/26/2023

71114.03 Miscellaneous Form 1903.062C Emergency Response Staffing Drill - December 19, 2022 12/19/2022

71114.03 Procedures 1903.062 Communications System Operating Procedure 38

71114.03 Procedures 1903.080 Emergency Operations Facility (EOF) Activation 4

71114.03 Procedures EN-EP-310 Emergency Response Organization Notification System 11

71114.04 Corrective Action CR-ANO-1-2018-04843, 1-2020-01781

Documents

71114.04 Miscellaneous 10 CFR 50.54(q) Screening, Procedure/Document 04/07/2023

Number: EPLAN; Revision: 048; Title: ANO Emergency

Plan

71114.04 Miscellaneous 10 CFR 50.54(q) Evaluation, Procedure/Document 04/07/2023

Number: EPLAN; Revision: 048; Title: ANO Emergency

Plan

71114.04 Miscellaneous 10 CFR 50.54(q) Screening, Procedure/Document 05/24/2022

Number: OP-1903.010; Revision: 060; Title: Emergency

Action Level Classification

71114.04 Miscellaneous 10 CFR 50.54(q) Screening, Procedure/Document 12/18/2021

Number: ANO Emergency Plan; Revision: 46; Title: ANO

Emergency Plan

71114.04 Miscellaneous 10 CFR 50.54(q)(3) Evaluation, Procedure/Document 05/04/2022

Number: OP-1903.010; Revision: 060; Title: Emergency

Action Level Classification

71114.04 Miscellaneous 10 CFR 50.54(q)(3) Evaluation, Procedure/Document 12/08/2021

Number: ANO Emergency Plan; Revision: 46; Title: ANO

Emergency Plan

71114.04 Miscellaneous 10 CFR 50.54(q)(2) Review, Procedure/Document 01/27/2021

Number: OP-1903.053; Revision: 009; Title: Logistical

Support

71114.04 Miscellaneous 10 CFR 50.54(q)(3) Evaluation, Procedure/Document 11/29/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

Number: EN-EP-801; Revision: 018; Title: Emergency

Response Organization

71114.04 Miscellaneous 10 CFR 50.54(q) Screening, Procedure/Document 01/18/2023

Number: 1903.010/1903.010-U1 Wall Chart; Revision:

061/001; Title: Emergency Action Level Classification

71114.04 Miscellaneous 10 CFR 50.54(q)(3) Evaluation, Procedure/Document 01/18/2023

Number: 1903.010 & 1903.010 U1 WC; Revision: 061 &

001; Title: Emergency Action Level Classifications & Unit

Wall Chart

71114.04 Miscellaneous 0CAN032301 Emergency Plan Implementing Procedure Revision; 03/02/2023

Arkansas Nuclear One - Units 1 and 2; Docket Nos. 50-

313, 50-368, and 72-13; Renewed Operating Facility

License Nos. DPR-51 and NPF-6

71114.04 Miscellaneous 0CAN052302 Arkansas Nuclear One (ANO) Emergency Plan Rev. 48; 05/11/2023

Arkansas Nuclear One - Units 1 and 2; NRC Docket

Nos. 50-313 and 50-368; Renewed Facility Operating

License Nos. DPR-51 and NPF-6

71114.04 Miscellaneous 1CNA122203 Arkansas Nuclear One, Unit 1 - Issuance of Amendment 12/09/2022

No. 278; RE: Revision to Technical Specifications 3.4.12

and 3.4.13 Based on Revised Dose Calculations (EPID

L-2021-LLA-0181)

71114.04 Procedures EN-EP-305 Emergency Planning 10CFR50.54(q) Review Program 8

71114.04 Procedures OP-1903.010 Emergency Action Level Classification 59, 60, 61

71114.05 Corrective Action CR-ANO-1-2021-00341, 1-2021-03102, 1-2022-01040, 1-2022-

Documents 01068, 1-2022-02978, 1-2023-00172, 1-2023-00183, 1-

23-00221, 1-2023-00273, 1-2023-00383, 1-2023-

00410, 1-2023-01045, 2-2022-00042, 2-2022-01132, 2-

23-00245, 2-2023-01937, 2-2023-02189, 2-2023-

250, C-2021-02305, C-2022-01881, C-2022-02072,

C-2022-02272, C-2022-02351, C-2022-02492, C-2022-

2505, C-2022-03107, C-2023-00964

71114.05 Corrective Action CR-ANO-C-2023-03166, C-2023-03168, C-2023-03178

Documents

Inspection Type Designation Description or Title Revision or

Procedure Date

Resulting from

Inspection

71114.05 Miscellaneous ETE Update State and Local Agreement 03/20/2023

71114.05 Miscellaneous 23TTD3 Blue Team Tabletop Drill, Entergy Corporation, 08/29/2023

Arkansas Nuclear One, 8/29/23

71114.05 Miscellaneous Arkansas Nuclear One (ANO) HP/RP Environmental Drill 09/08/2020

Report, 08/06/2020

71114.05 Miscellaneous Arkansas Nuclear One HP/Post Accident Drill Report, 09/08/2020

08/04/2020

71114.05 Miscellaneous Arkansas Nuclear One (ANO) Onsite Medical Drill 10/26/2020

Report, 10/13/2020

71114.05 Miscellaneous ANO (Arkansas Nuclear One) ERO Green Team Site 12/03/2020

Drill Report, 11/11/2020

71114.05 Miscellaneous 2023 ANO Health Physics - In Plant Monitoring (First 06/19/2023

Half), Entergy Corporation, Arkansas Nuclear One,

06/07/2023

71114.05 Miscellaneous ANO 2023 Red Team 2nd Quarter PI Drill, Entergy 06/28/2023

Corporation, Arkansas Nuclear One, 06/22/2023

71114.05 Miscellaneous EOF 4th Quarter - PI Drill Green Team, Entergy 01/06/2022

Corporation, Arkansas Nuclear One, 12/16/2021

71114.05 Miscellaneous Arkansas Nuclear One (ANO) 10 CFR 50.54(h)(h)(2) 04/20/2021

Drill Report, 03/31/2021

71114.05 Miscellaneous Arkansas Nuclear One (ANO) HP/RP Environmental Drill 06/24/2021

Report, 06/03/2021

71114.05 Miscellaneous Arkansas Nuclear One HP/Post Accident Drill Report, 04/07/2021

03/09/2021

71114.05 Miscellaneous Onsite Medical Drill/HP Drill 12-6-2021, Entergy 03/10/2022

Corporation, Arkansas Nuclear One, 12/06/2021

71114.05 Miscellaneous ANO 2022 Environmental (Radiological Monitoring), 06/28/2022

Entergy Corporation, Arkansas Nuclear One, 06/01/2022

71114.05 Miscellaneous ANO 2022 Health Physics - In Plant Monitoring (First 06/29/2022

Half), Entergy Corporation, Arkansas Nuclear One,

06/16/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

71114.05 Miscellaneous ANO 2022 Health Physics - In Plant Monitoring (Second 12/13/2022

Half), Entergy Corporation, Arkansas Nuclear One,

2/06/2022

71114.05 Miscellaneous Onsite Medical Drill 12/6/2022, Entergy Corporation, 05/04/2023

Arkansas Nuclear One, 12/06/2022

71114.05 Miscellaneous ANO 2022 Post Accident Sampling Drill, Entergy 01/04/2023

Corporation, Arkansas Nuclear One, 12/08/2022

71114.05 Miscellaneous CNRO2022-00016 Evacuation Time Estimate Reports 09/12/2022

71114.05 Miscellaneous EP-005 Control Room Emergency Response Facility 03/29/2021

Walkthrough, March 20, 2021

71114.05 Miscellaneous EP-008 EOF Emergency Response Facility Walkthrough, March 03/18/2022

16, 2022

71114.05 Miscellaneous EP-020 JIC Emergency Response Facility Walkthrough, 02/13/2023

February 9, 2023

71114.05 Miscellaneous EP-2021-033 1903.004-G Annual EAL Review 12/14/2021

71114.05 Miscellaneous Form 1903.004-M ETE Update 04/02/2023

71114.05 Miscellaneous KLD TR-1167 Arkansas Nuclear One 2020 Population Update Analysis 09/19/2020

71114.05 Miscellaneous NQ-2021-007 QA Audit Report QA-07-2021-ANO-1, 2021 QA Audit of 05/06/2021

Emergency Preparedness at Arkansas Nuclear One

(ANO)

71114.05 Miscellaneous NQ-2023-008 QA Audit Report QA-7-2023-ANO-1, 2023 QA Audit of 05/11/2023

Emergency Preparedness Programs at Arkansas

Nuclear One (ANO)

71114.05 Miscellaneous QS-2022-ANO-002 Quality Assurance Surveillance Report, Activity: 2022 04/04/2022

Emergency Preparedness Surveillance, Dates: 3/28/22

to 4/4/22

71114.05 Procedures 1903.062 Communications System Operating Procedure 38

71114.05 Procedures 1903.069 Equipment Important to Emergency Response 9, 10

71114.05 Procedures 1904.002 Offsite Dose Projections 51

71114.05 Procedures EN-EP-202 Equipment Important to Emergency Response (EITER) 4

71114.05 Procedures EN-EP-202-01 ANO EITER Matrix 0

71114.05 Procedures EN-EP-306 Drills and Exercises 11

71114.05 Procedures EN-EP-603 Declared Emergency Recovery and Re-entry 1

71114.05 Procedures EN-EP-610 Technical Support Center (TSC) Operations 7, 8

Inspection Type Designation Description or Title Revision or

Procedure Date

71114.05 Procedures EN-FAP-EP-005 Emergency Preparedness Performance Indicators 13-17

71114.05 Procedures EN-FAP-LI-001 Performance Improvement Review Group (PRG) 21

Process

71114.05 Procedures EN-LI-102 Corrective Action Program 49

71114.05 Procedures EN-LI-121 Tending and Performance Review Process 31

71114.05 Procedures EN-QV-109 Audit Process 42

71114.05 Procedures OP-1903.004 Admin. & Maintenance of Emergency Plan & 37

Implementing Procedures

71114.05 Procedures OP-1903.080 Emergency Operations Facility (EOF) Activation 4

71114.05 Work Orders Work Order Number 535066, 566529, 581716, 582258, 591346, 596438,

54030331

71114.06 Procedures OP-1903.010 Emergency Action Level Classification 62

71114.06 Procedures OP-1903.011 Emergency Response/Notifications 63

71114.06 Procedures OP-2203.024 Loss of Turbine Load 16

71151 Corrective Action CR-ANO-C-2022-03406, C-2023-00782, C-2023-00779

Documents

71151 Miscellaneous Blue Team EOF PI Drill, Entergy Corporation, Arkansas 09/14/2022

Nuclear One, 09/01/2022

71151 Miscellaneous Red Team EOF PI Drill, Entergy Corporation, Arkansas 12/12/2022

Nuclear One, 12/01/2022

71151 Miscellaneous Blue Team EOF PI Drill, Entergy Corporation, Arkansas 12/12/2022

Nuclear One, 12/06/2022

71151 Miscellaneous 2023 ANO 23FSD1 Green Team, Entergy Corporation, 04/06/2023

Arkansas Nuclear One, 03/07/2023

71151 Miscellaneous 2023 ANO 23FSD2 Yellow Team, Entergy Corporation, 06/26/2023

Arkansas Nuclear One, 06/06/2023

71151 Miscellaneous ANO Performance Indicator Report for 3Q22 10/12/2022

71151 Miscellaneous ANO Performance Indicator Report for 1Q23 04/20/2023

71151 Miscellaneous ANO Performance Indicator Report for 2Q23 07/18/2023

71151 Procedures EN-EP-801 Emergency Response Organization 18

71151 Procedures EN-FAP-EP-005 Emergency Preparedness Performance Indicators 17

71151 Procedures EN-LI-114 Regulatory Performance Indicator Process 17-21

71151 Procedures EP-019 Emergency Planning Performance Indicators 5, 6, 7

Inspection Type Designation Description or Title Revision or

Procedure Date

71152S Corrective Action CR-ANO-C-2023-03025

Documents

71153 Corrective Action CR-ANO-2-2023-02453, 2-2023-02457

Documents

71153 Procedures OP-2102.004 Power Operation 75

71153 Procedures OP-2103.018 RCS Flow Rate Calculation 11

71153 Procedures OP-2203.025 RCP Emergencies 21

31