IR 05000313/2019002

Integrated Inspection Report No. 05000313/2019002 and 05000368/2019002

ML19214A275
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/01/2019
From:	John Dixon NRC Region 4
To:	Richard Anderson Entergy Operations
References
IR 2019002
Download: ML19214A275 (37)

Text

ust 1, 2019

SUBJECT:

ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000313/2019002 AND 05000368/2019002

Dear Mr. Anderson:

On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Arkansas Nuclear One, Units 1 and 2. On July 9, 2019, the NRC inspectors discussed the results of this inspection with Mr. B. Patrick, Director, Regulatory Assurance and Performance Improvement, and other members of your staff. The results of this inspection are documented in the enclosed report.

Two findings of very low safety significance (Green) are documented in this report. Both findings involved violations of NRC requirements. The inspectors also documented a licensee-identified violation, which was determined to be of very low safety significance, in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or significance of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Arkansas Nuclear One.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Arkansas Nuclear One. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

John L. Dixon, JR, Chief Reactor Projects Branch D Docket Nos.: 05000313 and 05000368 License Nos.: DPR-51 and NPF-6

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000313 and 05000368 License Numbers: DPR-51 and NPF-6 Report Numbers: 05000313/2019002 and 05000368/2019002 Enterprise Identifier: I-2019-002-0005 Licensee: Entergy Operations, Inc.

Facility: Arkansas Nuclear One, Units 1 and 2 Location: Russellville, AR Inspection Dates: April 1, 2019 to June 30, 2019 Inspectors: T. DeBey, Resident Inspector N. Greene, Senior Health Physicist S. Hedger, Emergency Preparedness Inspector C. Henderson, Senior Resident Inspector J. ODonnell, Health Physicist T. Sullivan, Resident Inspector Approved By: John L. Dixon, JR, Chief Reactor Projects Branch D Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Arkansas Nuclear One, Units 1 and 2 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC and self-revealed findings and violations are summarized in the tables below. A licensee-identified non-cited violation is also documented.

List of Findings and Violations Failure to Properly Evaluate Operability of the Unit 1 Emergency Diesel Generator 2 Room Ventilation System Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.4] - Trending 71111.15 Systems NCV 05000313/2019002-01 Open/Closed The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to complete an adequate operability evaluation in accordance with Procedure EN-OP-104, Operability Determination Process, Revision 16. Specifically, the licensee failed to complete an adequate operability evaluation and to identify the temperature switch TS-7904 for emergency diesel generator 2 exhaust fan VEF-24D as a degraded nonconforming condition for multiple failures to maintain its calibration.

Failure to Perform Procedural Steps in Sequence during Surveillance Testing Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71153 Systems NCV 05000313/2019002-02 Complacency Open/Closed The inspectors reviewed a self-revealed, Green finding and associated non-cited violation of Arkansas Nuclear One Unit 1, Technical Specification 5.4.1.a, for the licensees failure to implement Procedure OP-1304.206, Unit 1 EFIC Channel B Monthly Test, SG Pressure Greater Than 750 PSIG, Revision 32. Specifically, the licensee failed to perform procedural steps in Procedure OP-1304.206 in sequence, which resulted in the inadvertent actuation of the turbine driven emergency feedwater pump P-7A, which started feeding both steam generators.

Additional Tracking Items None.

PLANT STATUS

Unit 1 began the inspection period at full power. On May 2, 2019, power was lowered to 85 percent to perform scheduled main turbine throttle and governor valve surveillance testing and was then returned to full power operation.

Unit 2 began the inspection period at full power. On May 6, 2019, power was lowered to 18 percent to facilitate an oil leak repair for reactor coolant pump C. Unit 2 was returned to full power on May 7, 2019. On May 26, 2019, Unit 2 had an automatic reactor trip from 100 percent power after reactor coolant pump B tripped on a ground fault. The unit transitioned to Forced Outage 2F19-01 to troubleshoot and repair reactor coolant pump B ground fault, repair reactor coolant pump C oil leak, and replace all reactor coolant pump control bleed-off lines.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection Impending Severe Weather Sample (IP Section 03.03)

Unit 1 and Unit 2 Arkansas River flooding and potential severe weather on May 29, 2019.

Seasonal Extreme Weather Sample (IP Section 03.02) (1 Sample)

The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal hot temperatures for the following systems on April 25, 2019:

• Unit 2 refueling water storage tank;

• Unit 1 borated water storage tank;

• Unit 1 and Unit 2 quality condensate storage tank.

Summer Readiness Sample (IP Section 03.01) (1 Sample)

The inspectors evaluated summer readiness of offsite and onsite alternating current

(ac) power systems on June 18, 2019.

71111.04 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

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

(1) Unit 2 high pressure safety injection pump C aligned to train A during containment spray pump A maintenance and surveillance testing on April 29, 2019;

(2) Unit 2 train B containment spray system during train A containment spray maintenance on June 3, 2019;

(3) Unit 2 engineering safety feature room A, B, and C safety-related ventilation system on June 11, 2019;

(4) Unit 1 emergency diesel generator 2 exhaust fan D on June 18, 2019;

(5) Unit 2 control element assemblies operating on the lower gripper on June 28, 2019.

71111.04S - Equipment Alignment Complete Walkdown Sample (IP Section 03.02)

Unit 2 low pressure safety injection system on May 30, 2019.

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Unit 1 radwaste processing area, Fire Zone 20-Y, Fire Area C, on April 8, 2019;

(2) Unit 1 upper north piping penetration room, Fire Zone 79-U, Fire Area B-1, on April 11, 2019;

(3) Unit 1 lab and demineralizer access area, Fire Area 67-U, Fire Area B-9, on April 11, 2019;

(4) Unit 2 engineering safety features Room A, Fire Zone 2014-LL, Fire Area B-6, on May 15, 2019;

(5) Unit 2 engineering safety features Room C, Fire Zone 2010-LL, Fire Area B-6, on May 15, 2019;

(6) Unit 2 engineering safety features Room B, Fire Zone 2007-LL, Fire Area AA, on May 16, 2019.

71111.06 - Flood Protection Measures Inspection Activities - Internal Flooding (IP Section 02.02a.)

The inspectors evaluated internal flooding mitigation protections in the:

Unit 1 breaching of train bay hatch HTC-492 in support of maintenance activities on April 22, 2019.

71111.07A - Heat Sink Performance Annual Review (IP Section 02.01)

The inspectors evaluated readiness and performance of:

Unit 2 engineering safety features room A, B, and C room coolers on May 30, 2019.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1) Unit 1 down power to 85 percent thermal rated power for main turbine bypass valve and governor valve surveillance testing on May 2, 2019;

(2) Unit 2 down power to 18 percent thermal rated power for reactor coolant pump C oil leak repair on May 7, 2019.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

Unit 1 licensed operator requalification scenario on April 16, 2019.

71111.12 - Maintenance Effectiveness Quality Control (IP Section 02.02)

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance activities:

(1) Unit 1 and Unit 2 General Electric magne-blast 4160 volt breakers due to bent stop pin identified in Unit 1 high pressure injection pump C breaker preventing it from closing on May 30, 2019;

(2) Unit 1 high pressure injection pump motors on May 30, 2019.

Routine Maintenance Effectiveness Inspection (IP Section 02.01) (1 Sample)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

Unit 2 low pressure safety injection system on May 17, 2019.

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Unit 1 high pressure injection pump B motor replacement and rigging and lifting of motor through hatch HTC-492 on April 11, 2019;

(2) Unit 2 emergent work for train A service water loop supply line to the containment coolers A and B pin hole through wall leak in the lower south piping penetration room on April 24, 2019;

(3) Unit 2 emergent work for control element assemblies 11 and 40 transferring from the upper gripper coil to the lower gripper coil and an unplanned 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> limiting condition for operation entry on April 24, 2019;

(4) Unit 2 high integrated risk for control element assembly 43 ACTM card replacement and transferring five control element assemblies to the lower gripper on April 26, 2019;

(5) Unit 2 Yellow risk for train A containment spray system maintenance outage on April 29, 2019;

(6) Unit 1 emergent work for reactor protection system Channel D nuclear instrument NI-8 causing spurious channel trips on April 30, 2019.

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 2 containment spray pump B inlet check valve excessive clearance operability on April 4, 2019;

(2) Unit 1 high pressure injection pump C and reactor building spray pump B elevated pump vibrations operability on April 9, 2019;

(3) Unit 2 low pressure safety injection pumps A and B recirculation actuation system relays lead termination on April 24, 2019;

(4) Unit 1 train B emergency diesel generator fan coil D temperature limit instrument drift operability on May 2, 2019;

(5) Unit 2 containment spray pumps A and B seal oil coolers re-assembled with the incorrect torqueing requirements operability on May 9, 2019;

(6) Unit 2 train A service water loop supply line to containment coolers A and B pin hole through wall leak in the lower south piping penetration room operability on May 31, 2019;

(7) Unit 2 control element assemblies operating on the lower gripper drop time testing operability on June 28, 2019.

71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

The inspectors evaluated the following temporary or permanent modifications:

(1) Unit 2 temporary modification of reactor coolant pump C access cover on May 9, 2019;

(2) Unit 1 permanent modification of high pressure injection pump B motor replacement on May 28, 2019.

71111.19 - Post-Maintenance Testing Post Maintenance Test Sample (IP Section 03.01)

The inspectors evaluated the following post maintenance tests:

(1) Unit 1 reactor building spray pump A motor balancing maintenance on April 16, 2019;

(2) Unit 2 train B service water piping return header from emergency control room chiller B weld repair on April 22, 2019;

(3) Unit 1 high pressure injection pump B motor replacement on April 25, 2019;

(4) Unit 2 emergent work for control element assembly 40 transferring to the lower gripper on April 25, 2019;

(5) Unit 2 control element assembly 43 ACTM card replacement and transferring five control element assemblies to the lower gripper on April 26, 2019;

(6) Unit 2 containment spray pump A motor preventive maintenance on April 30, 2019;

(7) Unit 2 containment spray pump A seal cooler post maintenance testing on May 1, 2019;

(8) Unit 2 containment spray pump A breaker 2A-304 protective relay preventive maintenance on May 1, 2019.

==71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01) (1 Partial)

Unit 2 evaluated Forced Outage 2F19-01 activities from May 26 to June 30, 2019. The inspectors completed inspection procedure Sections 03.01.a and 03.01.c.

==71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests:

==

Inservice Testing (IP Section 03.01)==

Unit 2 low pressure safety injection pump A inservice testing surveillance on April 5, 2019.

Surveillance Tests (other) (IP Section 03.01) (5 Samples)

(1) Unit 2 train A low pressure safety injection and refueling water tank valve stroke surveillance on April 5, 2019;

(2) Unit 2 containment spray pump A surveillance testing on May 8, 2019;

(3) Unit 2 emergency feedwater system to auxiliary feedwater boundary check valve surveillance testing corrective actions on June 4, 2019;

(4) Unit 1 train A and B service water cross-tie valves CV-3640, CV-3642, CV-3644, CV-3644 leakage surveillance testing on June 6, 2019;

(5) Unit 1 emergency diesel generator 2 exhaust fan D temperature instrument calibration surveillance on June 18, 2019.

71114.04 - Emergency Action Level and Emergency Plan Changes Inspection Review (IP Section 02.01-02.03)

The licensee submitted a summary of emergency plan changes (Revision 43) to the NRC on April 4, 2019. The inspectors conducted an in-office review of the changes from April 22 to May 15, 2019. This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

Unit 1 loss of coolant accident concurrent with a loss of offsite power with multiple equipment failures on May 15,

71124.02 - Occupational ALARA Planning and Controls Radiological Work Planning (IP Section 02.01)

The inspectors evaluated the licensees radiological work planning by reviewing the following activities:

• RWP 2017-2500, 2E-35 A/B Replacement Activities during 2R25;

• RWP 2018-1404, Maintenance Activities 1R27 (Bulk Work);

• RWP 2018-2430, 2R26 Reactor Disassembly/Reassembly;

• RWP 2018-2903, Inspections/Repair of Reactor Vessel Closure Head (RVCH)

Nozzle #49.

Verification of Dose Estimates and Exposure Tracking Systems (IP Section 02.02)

(1 Sample)

The inspectors evaluated dose estimates and exposure tracking. The inspectors reviewed the following ALARA planning documents:

• RWP 2017-2500, 2E-35 A/B Replacement Activities during 2R25;

• RWP 2018-1404, Maintenance Activities 1R27 (Bulk Work);

• RWP 2018-2430, 2R26 Reactor Disassembly/Reassembly;

• RWP 2018-2903, Inspections/Repair of Reactor Vessel Closure Head (RVCH)

Nozzle #49.

Additionally, the inspectors reviewed the following radiological outcome evaluations:

• 1R26 ALARA Report, 2016;

• 1R27 ALARA Report, 2018;

• 2R25 ALARA Report, 2017;

• 2R26 ALARA Report, 2018.

71124.04 - Occupational Dose Assessment External Dosimetry (IP Section 02.02)

The inspectors evaluated the external dosimetry program implementation.

Internal Dosimetry (IP Section 02.03) (1 Sample)

The inspectors evaluated the internal dosimetry program implementation.

Whole Body Counts ID Date

===23721 11/14/2018

23089 10/20/2018

20639 3/28/2018

23799 10/19/2018

24295 5/5/2018 In-vitro internal monitoring ID Date Sample No.

24610 4/5/2018 FIS 2499

24109 4/7/2018 SMI 7572 Dose assessments performed using air sampling and DAC-hr monitoring

• None were available during this inspection Source Term Categorization (IP Section 02.01) ===

The inspectors evaluated the licensees characterization of the source term and use of scaling factors for the use of hard-to-detect radionuclide activity.

Special Dosimetric Situations (IP Section 02.04) (1 Sample)

The inspectors evaluated special dosimetric situations.

Declared pregnant workers: ID Date

===21082 10/27/2018

23810 10/27/2018 EDEX exposures:

ID Date

24625 10/13/2019

24628 10/13/2019 Shallow Dose Equivalent:

ID Date Assessment No.

24458 10/19/2018 2018-057

24309 10/25/2018 2018-064 Neutron Dose Assessment:

ID Date

29595 2H18

21914 2H18

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)

=

(1) Unit 1 (April 1, 2018 - March 31, 2019);

(2) Unit 2 (April 1, 2018 - March 31, 2019).

BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)

(1) Unit 1 (April 1, 2018 - March 31, 2019);

(2) Unit 2 (April 1, 2018 - March 31, 2019).

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (2 Samples)

(1) Unit 1 (April 1, 2018 - March 31, 2019);

(2) Unit 2 (April 1, 2018 - March 31, 2019).

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 02.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

Unit 1 and Unit 2 service water pump dissimilar metal connection for pump bowl and column on May 31, 2019.

Semiannual Trend Review (IP Section 02.02) (1 Sample)

Unit 1 and Unit 2 potential adverse trend in human performance events on June 28, 2019.

71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)

(1) Unit 1 automatic actuation of the steam driven emergency feedwater pump during emergency feedwater initiation and control Channel B testing on June 12, 2019;

(2) Unit 2 automatic reactor trip due to a ground fault trip of reactor coolant pump B on May 26,

INSPECTION RESULTS

Licensee-Identified Non-Cited Violation 71124.02 This violation of very low safety significance was identified by the licensee, has been entered into the licensees corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Technical Specification 5.4.1(a) requires, in part, that written procedures shall be implemented covering applicable procedures recommended in Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Revision 2, Appendix A, February 1978. Section 7(e) of Regulatory Guide 1.33 covers Radiation Protection Procedures.

Contrary to the above, during Refueling Outage 2R20 in October 2009, the licensee failed to implement written procedures for radiation protection when they free released a radioactively contaminated eddy current probe from the radiologically controlled area (RCA), and subsequently shipped it offsite for maintenance, in August 2018, without proper controls.

Specifically, the licensee primarily failed to implement the following requirements, in part, in licensee Procedure EN-RP-121, Radioactive Material Control, Revision 4 (effective 11/04/2008), and Revision 15 (effective 12/11/2018):

• Revision 4, Section 5.7.4 - Unconditional release of materials other than personal items SHALL be released with the following applicable requirements met:

• Prior to releasing items that have been inside the RCA, ensure the material has been properly surveyed;

• Item has no detectable loose or fixed contamination greater than the established minimum sensitivity of the combined survey method and instrument.

• Revision 4, Section 5.7.7 - Conditional release of radioactive material (RAM) is allowed from the RCA if the material is properly labeled.

• Revision 15, Section 5.5.1 - All radioactive material shall be properly labeled prior to being transported from one location to another.

• Revision 15, Section 5.6.1 - For Control and Release of Material, items may be considered for free release as long as ALL of the following criteria are met:

• No detectable fixed activity above background, other than naturally occurring isotopes;

• No detectable suspected internal contamination;

• No radioactive labels or markings.

In addition, the licensee's procedure defines RAM, in part, as any item or material which satisfies the following conditions:

• Has detectable contamination, fixed or loose, greater than the minimum sensitivity of the survey instrument, OR causes a validated alarm on an automated monitor;

• Has been evaluated to have inaccessible areas that may have become contaminated.

On October 3, 2018, the radioactively contaminated eddy current probe was found to have fixed contamination and alarmed the gamma small articles monitor when surveyed at the request of the nondestructive examination (NDE) group who asked the radiation protection (RP) group to perform surveys on their instrumentation as part of their baseline survey program. The licensee determined that the probe had been stored outside of the RCA since 2009 in the NDE laboratory, untagged as RAM, which violated radiation protection procedures. RP identified the presence of 600 ccpm (corrected counts per minute) of Cs-137 on the eddy current probe. As a result, the probe was tagged as RAM and controlled in a radioactive materials area.

NRC's Inspection Manual Chapter 0609, Appendix D, Public Radiation Safety, states that at a licensee's facility, any equipment or material that came into contact with licensed radioactive material or that had the potential to be contaminated with radioactive material of plant origin and are to be removed from the facility, and must be surveyed for the presence of licensed radioactive material prior to shipment from the facility. In assessing the significance of the performance deficiency, the inspectors determined that the finding was Green, of very low safety significance, because although it involved a failure in radioactive materials control and was transported from the site, surface contamination levels were less than 5 times any limits and there was no radiation exposure above 1 percent of any occupational or public dose limit (less than 0.005 rem).

As immediate corrective actions, the licensee reviewed and updated their procedures to enhance the requirements of surveying equipment, tooling, and components. They also conducted a strategic sweep survey of instrumentation stored in areas of interest outside of the RCA with high sensitivity instruments to avoid future instances of failed controls. No additional radioactive material was identified. These actions were documented in their evaluation via Condition Report CR-ANO-2-2018-02545-01.

Significance: Green Corrective Action References: Condition Report CR-ANO-2-2018-02545 Observation: Semiannual Trend Review 71152 The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, and other documentation available to help identify performance trends that might indicate the existence of a more significant safety issue. The inspectors verified that the licensee was taking corrective actions to address the identified adverse trends. The inspectors did not review any cross-cutting themes because none existed at the site.

To verify that the licensee was taking corrective actions to address identified adverse trends that might indicate the existence of a more significant safety issue, the inspectors reviewed the corrective action program documentation associated with a potential adverse trend in human performance events from the time period of December 2018 through June 2019.

Examples of these events included:

• CR-ANO-2-2019-01359. During performance of Procedure OP-2304.065, maintenance personnel mis-identified the terminal board layout in cabinet 2C99B.

This resulted in the incorrect lead being de-terminated and operations notified maintenance personnel. The leads were re-terminated, and work was stopped. In response, the licensee performed a human performance analysis with Performance Improvement Review Group (PRG) review.

• CR-ANO-2-2019-01432. During the performance of the cold shutdown test Procedure OP-2102.010, Attachment F, Auxiliary Spray and Charging Bypass Check Valve Test, the charging system flow path was inadvertently isolated resulting in charging pump C supply breaker tripping and charging pump A discharge relief valve opening. The licensee classified this condition report as an adverse condition -

Advance Broke Fix to investigate the human performance and process deficiencies.

• CR-ANO-1-2019-01418. During troubleshooting of temperature switch TSL-5261 Unit 1 emergency diesel generator (EDG) 2 jacket water temperature low switch, maintenance personnel discovered that the temperature switch wiring was incorrect at the switch terminations. Upon further review, it was identified that the lifted lead log was filled out incorrectly while performing Procedure OP-1304.135, EDG 2 Instrument Calibration. This condition resulted in the re-termination being incorrect when maintenance personnel on the next shift re-installed switch TSL-5261 in accordance with the log. This condition report was closed to CR-ANO-2-2019-01359 due to similar human performance issues identified.

• CR-ANO-1-2019-01515. While preparing to sample SPING 3 (RX-9830, Unit 1 fuel handling area ventilation radiation monitor) via the alternate sampling pump, a chemist closed SS-9830B (sample isolation valve V-13), which was not part of the procedure in use by the chemist. The chemist restored the valve to its original position when discovering that testing was in progress. This disabled the sampling required by the Offsite Dose Calculation Manual. The SPING 3 was in a nonfunctional status at the time of the valve manipulation, and operators secured the spent fuel pool exhaust fan which resulted in a condition where Offsite Dose Calculation Manual requirements no longer apply.

• CR-ANO-C-2019-02098 and CR-ANO-C-2019-02144. The licensees Nuclear Independent Oversight identified maintenance personnel are not consistently applying human performance tools to mitigate risk.

The licensees immediate corrective actions for the recent potential adverse trend in human performance events included:

• Multiple work stoppage stand-downs to reinforce the use of human performance tools which occurred on March 4, 2019, May 9, 2019, and June 11, 2019. Specifically:

1. Pre-job brief/job site review - Ensure licensee personnel understand the task, required roles and responsibilities, plant impact, and human performance traps and tools. Take the time to examine your work area to identify and eliminate or mitigate all hazards.

2. Procedure use and adherence - Follow procedures as written without deviating from their intent. If the procedure cannot be performed as written or is unclear, stop and correct it or obtain guidance from your supervisor.

3. Verification and validation - Use verification methods to validate assumptions before, during, and after an action, such as self-check, peer check, concurrent and independent verification.

• All licensee personnel were required to sign a commitment letter to being an excellent nuclear professional after the May 9, 2019, stand down and prior to re-commencing work activities at the station. This commitment letter reinforced the use of human performance tools, avoiding complacency, taking accountability for performance, maintaining a safety-conscious work environment, and making a commitment to mitigating nuclear, radiological, industrial safety, and environmental risks.

The inspectors noted the following:

1. The licensees immediate actions have not reduced the number of human performance events that occurred after the stand downs where completed.

2. CR-ANO-C-2019-02144 human performance event trend condition report was

classified as a nonadverse condition, even though multiple human performance errors had consequences associated with them (i.e., lifting relief valves, tripping pump breakers, inadvertent initiation of emergency feedwater to an operating steam generator, and the loss of a safety-related 4160 volt bus until the EDG restored power). The inspectors questioned the classification of Condition Report CR-ANO-C-2019-02144 and whether it was appropriately classified as a nonadverse condition. However, the inspectors noted the licensee was performing a common cause analysis with an organizational programmatic screening as required for an adverse condition.

3. The inspectors questioned the long term sustainability and effectiveness of the corrective actions implemented by the common cause analysis documented in Condition Report CR-ANO-C-2018-02728. The licensees effectiveness review, completed on January 28, 2019, concluded that the corrective actions where effective. However, the licensees Nuclear Independent Oversight issued a quality assurance finding for corrective action plans that were not being implemented with rigor or having sustainable actions, which included corrective actions associated with common cause analysis documented in CR-ANO-C-2018-02728.

Failure to Properly Evaluate Operability of the Unit 1 Emergency Diesel Generator 2 Room Ventilation System Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.4] - Trending 71111.15 Systems NCV 05000313/2019002-01 Open/Closed The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to complete an adequate operability evaluation in accordance with Procedure EN-OP-104, Operability Determination Process, Revision 16. Specifically, the licensee failed to complete an adequate operability evaluation and to identify the temperature switch TS-7904 for emergency diesel generator 2 exhaust fan VEF-24D as a degraded nonconforming condition for multiple failures to maintain its calibration.

Description:

On April 15, 2019, the licensee performed an inspection and calibration of temperature switch TS-7904 for emergency diesel generator (EDG) 2 exhaust fan VEF-24D under Work Order (WO) 52794842. During inspection and calibration, the licensee identified temperature switch TS-7904 was 20 degrees out of the calibration range of 103 to 107 degrees Fahrenheit (F) (as found setpoint was 127 degrees F). This condition was above the required setpoint and above the Safety Analysis Report (SAR) maximum room temperature of 120 degrees F. Exhaust Fan VEF-24D was immediately declared inoperable and was re-calibrated to the required set point range to restore it to operable. The licensee initiated Condition Report CR-ANO-1-2019-00959 to document this issue in the corrective action program and assess operability.

The inspectors reviewed Condition Report CR-ANO-1-2019-00959, the licensing and design basis for the EDG exhaust fan units, the history of the inspection and calibration of temperature switch TS-7904, and the licensees operability evaluation Procedure EN-OP-104, Operability Determination Process, Revision 16. The inspectors noted the following:

• Procedure EN-OP-104, step 8.10.11, states, in part, a system, structure, or component (SSC) that has been identified as having reduced reliability is considered degraded or nonconforming and evaluated to determine whether a SSC is operable, and reduced reliability is indicated by multiple failures, repetitive failures, or failures that exceed the number of expected failures.

• Procedure EN-OP-104, step 8.1, states, in part, 1. Determine the impact of the degraded or nonconforming condition on the technical specification SSC or the specified safety function; and 2. Determine if there is an ongoing degradation mechanism that can impact: 1. Future operability based on changing conditions; and 2. SSCs specified safety functions and mission time.

• EDG 1 and 2 exhaust fans VEF-24A/B/C/D are safety related exhaust fans whose purpose is to support EDG operation by preventing their respective EDG rooms from exceeding 120 degrees F. Each EDG room has two redundant exhaust fans. In the event of a failure of the lead exhaust fan (VEF-24A/C), the backup fan (VEF-24B/D)would be sufficient to cool the respective room.

• Condition Reports CR-ANO-1-2018-04294 and CR-ANO-1-2018-05007 documented the inability of EDG exhaust fans VEF-24A/B/C/D to achieve the required Unit 1 SAR flow rates to maintain EDG operability when outside ambient temperature was greater than 85 degrees F. This issue was identified by the NRC design basis assurance inspection team and documented as non-citied violation 05000313/2018011-01.

• Temperature switch TS-7904 inspection and calibration were on a 5-year interval.

Further review of the inspection and calibration history by the inspectors identified temperature switch TS-7904 was out of calibration three of the last five intervals. The inspectors identified this condition as a degrading trend of the temperature switch drift in accordance with Procedure EN-OP-104, and the licensee did not identify this degraded condition. This information was not utilized by the licensee when assessing operability of exhaust fan VEF-24D and operability of EDG 2.

From the information above, the inspectors questioned the operability of exhaust fan VEF-24D to perform its safety function to start within its required temperature band to support operability of EDG 2 when outside ambient air temperature was greater than 85 degrees F and informed the licensee of their issue. In response to the inspectors question, the licensee entered this issue into their corrective action program as Condition Report CR-ANO-1-2019-01032 and immediately re-assessed operability of EDG 2.

The licensee determined temperature switch TS-7904 was subsequently calibrated to within its nominal range of 103 to 107 degrees F, but due to the as-found drift identified, it brought into question the reliability of the component and the undesirable consequences if temperature switch TS-7904 were to drift outside of its allowable temperature range. In response to this information the licensee declared EDG 2 operable-compensatory measure, with the compensatory measure implemented by Standing Order, VEF-24D EDG Exhaust Fan, to manually start exhaust fan VEF-24D any time EDG 2 was started automatically or manually.

Corrective Actions: The licensee implemented Standing Order, VEF-24D EDG Exhaust Fan, as a compensatory measure until temperature switch TS-7904 was replaced on June 6, 2019.

Corrective Action References: Condition Report CR-ANO-1-2019-01032

Performance Assessment:

Performance Deficiency: The licensees failure to identify a reduced-reliability, safety-related component as a degraded nonconforming condition and appropriately assessing operability is a performance deficiency.

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. Specifically, temperature switch TS-7904 reduced reliability, degrading instrument drift, and the as-found setpoint above the maximum allowed EDG room temperature of 120 degrees F.

Significance: The inspectors assessed the significance of the finding using Appendix A, Significance Determination of Reactor Inspection Findings for At - Power Situations. The finding was determined to be of very low safety significance (Green) because it:

(1) did not represent a deficiency affecting the design or qualification of a mitigating SSC;

(2) did not represent a loss of system and/or function;

(3) did not represent an actual loss of function of at least a single train for more than its technical specification allowed outage time OR two separate safety systems out-of-service for more than its technical specification allowed outage time; and

(4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Cross-Cutting Aspect: P.4 - Trending: The organization periodically analyzes information from the corrective action program and other assessments in the aggregate to identify programmatic and common cause issues. Specifically, the licensee failed to identify the trend of temperature switch TS-7904 being out of calibration on multiple events.

Enforcement:

Violation: Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances. The instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Procedure EN-OP-104, Operability Evaluation, Revision 16, an Appendix B, quality-related procedure, provides instructions for identifying SSC that require operability evaluation and how to assess operability. Procedure EN-OP-104 steps:

• 8.1, states, in part, 1. Determine the impact of the degraded or nonconforming condition on the technical specification SSC or the specified safety function; and 2. Determine if there is an ongoing degradation mechanism that can impact: 1. Future operability based on changing conditions; and 2. SSCs specified safety functions and mission time.

• 8.10.11, states, in part, an SSC that has been identified as having reduced reliability is considered degraded or nonconforming and evaluated to determine whether an SSC is operable, and reduced reliability is indicated by multiple failures, repetitive failures, or failures that exceed the number of expected failures.

Contrary to above, from April 15, 2019, to April 24, 2019, the licensee failed to implement Procedure EN-OP-104, steps 8.1 and 8.10.11. Specifically, the licensee failed to identify temperature switch TS-7904 for EDG 2 exhaust fan VEF-24D as degraded nonconforming condition for multiple failures to maintain its calibration and to complete an adequate operability evaluation. This condition resulted in the licensee declaring EDG 2 as operable-compensatory measure, with compensatory measure being to manually start exhaust fan VEF-24D anytime EDG 2 was started automatically or manually until the associated temperature switch was replaced.

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

Failure to Perform Procedural Steps in Sequence during Surveillance Testing Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71153 Systems NCV 05000313/2019002-02 Complacency Open/Closed The inspectors reviewed a self-revealed, Green finding and associated non-cited violation of Arkansas Nuclear One Unit 1, Technical Specification 5.4.1.a, for the licensees failure to implement Procedure OP-1304.206, Unit 1 EFIC Channel B Monthly Test, SG Pressure Greater Than 750 PSIG, Revision 32. Specifically, the licensee failed to perform procedural steps in Procedure OP-1304.206 in sequence, which resulted in the inadvertent actuation of the turbine driven emergency feedwater pump P-7A, which started feeding both steam generators.

Description:

On May 9, 2019, the licensee was performing emergency feedwater initiation and control (EFIC) Channel B surveillance testing in accordance with Procedure OP-1304.206. During the performance of this surveillance test the licensee inadvertently actuated the turbine driven emergency feedwater (EFW) pump P-7A and commenced feeding both once through steam generators. The licensees immediate actions were to secure EFW pump P-7A, to close both EFW steam admission valves, and to lower reactor power to 99 percent. The closure of the steam admission valves caused the licensee to declare them inoperable.

The licensee performed a prompt investigation to determine the preliminary cause of the inadvertent initiation of EFW pump P-7A and identified that a human performance error occurred during the performance of Procedure OP-1304.206, Section 8.8, ESAS Trip Test.

Licensee personnel failed to perform the following Procedure OP-1304.206 steps:

• 8.8.7 press and release train B EFW (EFW pump P-7A) reset pushbutton on the remote switch matrix;

• 8.8.8 verify the tripped 1 indicator on the EFW trip module in EFIC Channel B goes on solid after testing train B EFW bus 1.

These steps were not performed prior to performing step 8.8.9 press and release manual at the manual/auto pushbutton for the EFIC system train B EFW bus 2 trip. This resulted in both the EFIC system train B EFW bus 1 and bus 2 to trip at the same time, causing the actuation of the EFW pump P-7A and the unplanned feeding of both steam generators by the EFW system. The licensee entered this issue into their corrective action program as Condition Report CR-ANO-1-2019-01181, and performed an adverse condition analysis which identified the causal factors (CFs) of the event to be:

• CF 1: Clear Performance Standards - Clear performance standards were not consistently set and reinforced. Personnel responsible for oversight of the maintenance did not identify and correct degrading standards of performance in procedure use and adherence.

• CF 2: Inadequate Procedure Use and Adherence - Personnel were transitioning between reader-doer and performer-verifier modes during performance of the task without recognizing the inherent risk in this activity, leading to gaps in human performance tool use, unclear communications, and subsequent failure to perform the procedure as written.

• CF 3: Verbal Communication - Personnel did not utilize three-way communication to verify that the intended action was taken in the proper sequence.

Corrective Actions: The licensee halted the transient by securing EFW pump P-7A, closing both EFW steam admission valves, and lowering power to 99 percent. The licensee initiated an instrumentation and control work stoppage to allow management to assess the impacts of the error and to formulate a recovery plan to prevent future occurrences.

Corrective Action References: Condition Report CR-ANO-1-2019-01181

Performance Assessment:

Performance Deficiency: The licensees failure to perform procedural steps in sequence during EFIC Channel B monthly surveillance testing was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems cornerstone. Specifically, the licensee failed to perform procedural steps in sequence during EFIC Channel B monthly testing, resulting in the inadvertent actuation of the EFW pump P-7A, the unplanned feeding of both steam generators by the EFW system, and both EFW steam admission valves to be inoperable.

Significance: The inspectors assessed the significance of the finding using Appendix A, Significance Determination of Reactor Inspection Findings for At - Power Situations. The inspectors determined that the finding had very low safety significance (Green) because it:

(1) was not a design deficiency;

(2) did not represent a loss of system and/or function;

(3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and

(4) did not result in the loss of a high safety-significant, nontechnical specification train.

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, the licensee failed to use their human performance tools to ensure procedural steps were performed in sequence (i.e., failure to use three-way communications; not all personnel involved attended the pre-job brief; and the use of reader-doer instead of performer-verifier mode).

Enforcement:

Violation: Unit 1 Technical Specification 5.4.1.a requires, in part, that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix A to Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 9, states that maintenance that can affect the performance of safety related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. The licensee established Procedure OP-1304.206, Unit 1 EFIC Channel B Monthly Test, SG Pressure Greater Than 750 PSIG, Revision 32, to perform surveillance testing of the EFIC Channel B during power operations with steam generator pressures greater than 750 PSIG. Procedure OP-1304.206 provides the following steps:

• 8.8.7 press and release train B EFW (EFW pump P-7A) reset pushbutton, on the remote switch matrix prior to performing, and;

• 8.8.8 verify the tripped 1 indicator on the EFW trip module in EFIC Channel B goes on solid.

Contrary to the above, on May 9, 2019, the licensee failed to implement Procedure OP-1304.206, steps 8.8.7 and 8.8.8. This resulted in the inadvertent actuation of the EFW pump P-7A and the unplanned feeding of both steam generators by the EFW system.

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 May 9, 2019, the inspectors presented the radiation safety inspection results to Mr. B. Davis, Acting Site Vice President and Director of Engineering, and other members of the licensee staff.

• On May 15, 2019, the inspectors presented the emergency plan revision in-office review inspection results to Mr. A Sherrill, Manager, Emergency Preparedness, and other members of the licensee staff.

• On July 9, 2019, the inspectors presented the integrated inspection results to Mr. B. Patrick, Director, Regulatory Assurance and Performance Improvement, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Calculations CALC-92-E-0078- LPSI Pump NPSH Calculation 0

Corrective Action CR-ANO- 1-2018-04294, 1-2019-00959, 1-2019-01061, 1-2019-01032,

Documents 1-2019-01033, C-2019-01992, C-2019-01993

Corrective Action CR-ANO- 1-2019-01036, C-2019-01552

Documents

Resulting from

Inspection

Engineering EC-51913 Start-up Transformer #2 Non-Segregated Bus Duct Flood 0

Changes Modification

Procedures OP-1015.033 ANO Switchyard and Transformer Yard Controls 28

OP-1106.006 Emergency Feedwater Pump Operation 109

OP-1107.001 Electric System Operations 123

OP-1202.007 Degraded Power 15

OP-1203.007 Abnormal ES Bus Voltage and Degraded Offsite Power 14

OP-1203.025 Natural Emergencies 68

OP-1203.12H Annunciator K09 Corrective Action 50

OP-2017.001 Electrical System Operations 129

OP-2104.005 Containment Spray 83

OP-2106.006 Emergency Feedwater System Operations 100

OP-2203.008 Natural Emergencies 49

OP-2203.012F Annunciator 2K06 Corrective Action 40

OP-2203.054 Abnormal Grid 2

Work Orders WO 525596, 516790-15, 523470-01

71111.04 Calculations CALC-88-E-0032- LOCA Containment Analysis for ANO-2 SGR and Power 0

Uprate

CALC-91-E-0116- NPSH Calculation for HPSI and RB Spray 7

CALC-94-0094- Room 2010 Heat Load Evaluation 1

CALC-94-E-0095- Room 2007/2009 Heat Load Evaluation 1

Inspection Type Designation Description or Title Revision or

Procedure Date

CALC-94-E-0095- Room 2013/2014 Heat Load Evaluation 1

Corrective Action CR-ANO- 1-2019-00959, 1-2019-01061, 2-2019-00944, 2-2019-01084,

Documents 2-2019-01096

Corrective Action CR-ANO- 1-2019-01228, 1-2019-01032, 1-2019-01033, 2-2019-01264,

Documents 2-2019-01269

Resulting from

Inspection

Drawings M-2210 Sheet 2 P&ID Service Water System 86

M-2232 Sheet 1 P&ID Safety Injection System 122

M-2236 Sheet 1 P&ID Containment Spray System 95

Miscellaneous ULD-2-SYS-05 Containment Spray System 5

ULD-SYS-30 ANO Unit 2 Auxiliary Building HVAC System 9

Procedures OP-1104.036 Emergency Diesel Generator Operation 81

OP-2104.005 Containment Spray 83

OP-2104.039 HPSI System Operation 86, 87

OP-2104.040 LPSI System Operations 75

OP-2203.003 CEA Malfunction 24

OP-2203.012E Annunciator 2K05 Corrective Action 41

OP-2203.012F Annunciator 2K06 Corrective Action 40

Work Orders WO 52820434

71111.04S Calculations CALC-92-E-0078- LPSI Pump NPSH Calculation 0

Corrective Action CR-ANO- 2-2004-00065, 2-2012-03023, 2-2015-00070, 2-2016-02461,

Documents 2-2017-01180, 2-2017-02118, 2-2017-04416, 2-2018-00653,

2-2019-01003, 2-2019-01921, C-2018-01693,

Drawings M-2232, Sheet 1 P&ID Safety Injection 122

Engineering EC-72499 Replace 2P-60B LPSI Allis-Chambers Motor with New 0

Changes Siemens Motor WO-477487 Task 30

EC-74087 Recommended Standby Oil Level Band for 2P-35B and 2P- 0

60B

Miscellaneous ULD-2-SYS-04 Low Pressure Safety Injection and Shutdown Cooling 5

System

Procedures OP-2104.040 LPSI System Operations 75

Inspection Type Designation Description or Title Revision or

Procedure Date

OP-2107.001 Electrical System Operations 122

OP-2203.012E Annunciator 2K05 Corrective Action 41

OP-2203.012F Annunciator 2K06 Corrective Action 40

OP-2403.011 2P-60 A and B Low Pressure Safety Injection Motor 11

Maintenance

Work Orders WO 383683, 402313, 450476, 472947, 52680297,

71111.05Q Corrective Action CR-ANO- 2-2013-02426, 2-2015-00906, 2-2016-03077, 2-2019-00785

Documents

Corrective Action CR-ANO- 2-2019-01275, 2-2019-01282

Documents

Resulting from

Inspection

Fire Plans PFP-U1 ANO Prefire Plan (Unit 1) 21

PFP-U2 ANO Prefire Plan (Unit 2) 17

Miscellaneous Fire Impairment 3167 and 8054

Procedures COPD-024 Risk Assessment Guidelines 67

EN-DC-161 Control of Combustibles 19

EN-DC-330 Fire Protection Program 5

OP-1000.120 ANO Fire Impairment Program 25

OP-1003.014 ANO Fire Protection Program 9

OP-2405.016 Unit 2 Penetration Fire Barrier Visual Inspection 23

Work Orders WO 456698, 516652, 52600436

71111.06 Calculations CALC-95-R-0024- Basic Requirements for the Component Database on Station 16

Doors and Hatches

Corrective Action CR-ANO- 1-2019-00256, 1-2019-00911, C-2015-01888, C-2015-

Documents 01929, C-2019-00241, C-2019-00252, C-2019-01773, C-

2019-01976

Corrective Action CR-ANO- C-2019-00621

Documents

Resulting from

Inspection

Engineering EC-368727

Changes EC-58301 Review of Opening Hatch HTC-492 During Normal 0

Operation for HELB and Flooding Concerns Identified in CR-

Inspection Type Designation Description or Title Revision or

Procedure Date

ANO-C-2015-01888

EC-63132 Evaluate Internal Flooding Effects Due to CW Pipe Break or 0

Rupture on the Unit 1 and Unit 2 Turbine Buildings CR-ANO-

C-2016-00873

EC-74710 HELB Doors and Hatches Documents Clean-Up 0

Procedures OP-1015.052 Passive Barrier Breach Permitting Process 1, 2

OP-1104.018 Spent Resin Transfer Operations 24

Work Orders WO 368727, 512890

71111.07A Calculations CALC-91-R-2013- Service Water Performance Testing Methodology 29

CALC-94-0094- Room 2010 Heat Load Evaluation 1

CALC-94-E-0095- Room 2007/2009 Heat Load Evaluation 1

CALC-94-E-0095- Room 2013/2014 Heat Load Evaluation 1

Corrective Action CR-ANO 2-2012-01037, 2-2012-03023, 2-2017-01566

Documents

Corrective Action CR-ANO 2-2019-01265, 2-2019-01266

Documents

Resulting from

Inspection

Engineering EC-72776 Document the Results of the 2R25 As-Left Service Water 0

Changes Flow Test

EC-73958 Excess Airflow Effects on AB Room Cooler Thermal 0

Performance and Other Impacts Including Changes to SW

Methodology Report

EC-80295 Document the Results of the 2R26 As-Left Service Water 0

Flow Test WO 503112

Miscellaneous ULD-2-SYS-30 ANO Unit 2 Auxiliary Building HVAC System 9

Procedures OP-2104.005 Containment Spray 83

OP-2104.039 HPSI System Operation 87

OP-2104.040 LPSI System Operations 75

OP-2203.012E Annunciator 2K05 Corrective Action 41

Inspection Type Designation Description or Title Revision or

Procedure Date

OP-2305.062 Service Water System Flow Testing 3

Work Orders WO 392439, 503112, 52541048, 52736254

71111.12 Calculations CALC-91-EQ- Large Motors Program Resolution Project Plan 0

1001-01

Corrective Action CR-ANO- 1-2018-05167, 1-2019-00484, 1-2019-00531, 1-2019-00860,

Documents 2-2017-03691, 2-2018-02583, 2-2018-03739, 2-2018-04196,

2-2018-04446, 2-2018-04450, 2-2019-00328, 2-2019-00887,

2-2019-00889, 2-2019-00890, 2-2019-03337, 2-2019-03561,

C-2019-01219,

Corrective Action CR-ANO- 2-2019-00975

Documents

Resulting from

Inspection

Drawings M-2236, Sheet 1 P&ID Containment Spray System 95

Miscellaneous ULD-2-SYS-04 Low Pressure Safety Injection and Shutdown Cooling 5

System

Procedures EM-WM-107 Post Maintenance Testing 5

OP-2104.004 Shutdown Cooling System 64

OP-2104.040 LPSI System Operations 75

OP-2305.003 ESF Response Time Test 40

Work Orders WO 477487, 478089, 479504, 510351, 512119, 519804,

2770826,

71111.13 Corrective Action CR-ANO- 1-2019-00860, 1-2019-01056, 1-2019-01070, 1-2019-01073,

Documents 2-2019-00944, 2-2019-01073, 2-2019-01084, 2-2019-01096,

Engineering EC-80852 Temporary Support over HTC-483 for P-36B Motor 0

Changes Replacement

Procedures COPD-024 Risk Assessment Guidelines 67

EN-FAP-WM-002 Critical Evolutions 5

EN-OP-119 Protected Equipment Postings 10

EN-WM-104 On Line Risk Assessment 18

OP-1015.021 ANO-2 EOP/AOP User Guide 18

OP-1015.052 Passive Barrier Breach Permitting Process 1, 2

OP-2203.003 CEA Malfunction 24

Work Orders WO 522780, 523624, 52271362, 52790576, 52820434

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.15 Calculations CALC-88-E-0200- P-T Calculation for Unit 2 Service Water System 3

Corrective Action CR-ANO- 1-1993-00577, 1-1994-00168, 1-2002-00202, 1-2009-01061,

Documents 1-2016-02577, 1-2017-01323, 1-2018-00467, 1-2018-04294,

1-2019-00959, 2-2010-02863, 2-2010-02865, 2-2016-04277,

2-2018-03527, 2-2018-03532, 2-2018-03579, 2-2019-00675,

2-2019-00780, 2-2019-00856, 2-2019-00863, 2-2019-00935,

2-2019-00936, 2-2019-00937, 2-2019-00938, 2-2019-00948,

2-2019-00949, 2-2019-00951, 2-2019-00952, 2-2019-

00953, 2-2019-00954, 2-2019-00955, 2-2019-00956, 2-

2019-00957, 2-2019-00958, 2-2019-00959, 2-2019-01073,

2-2019-01084, 2-2019-01096, 2-2019-01171, 2-2019-01172,

C-2014-01256

CR-WF3- 2011-03190

Corrective Action CR-ANO- 1-2019-01032, 1-2019-01055, 2-2019-00975

Documents

Resulting from

Inspection

Drawings ISO 2HBC-76-2

ISO 2HCC-313-1

Engineering EC-73910 Baseline Reference Values for the ANO-1 IST Components 0

Changes

Engineering ER-ANO-2002- Evaluation of Fabricated Replacement Shells for 2E-47A and 0

Evaluations 00795-000 2E-48B

ER-ANO-2002- Use of 3/8 SA515 Gr 70 Plate on 2E-47E 0

00795-001

ER-ANO-2004-

0899-000

Miscellaneous Tagout SW-082 Repair Leak

Procedures CEP-WP-004 Weld Map 7.4

EN-DC-117 PMT and Special Instructions

EN-OP-104 Operability Determination Process 16

EN-WM-105 Planning

EN-WM-107 Post Maintenance Testing 5

Inspection Type Designation Description or Title Revision or

Procedure Date

OP-1104.005 Reactor Building Spray System Operation 82

OP-1104.036 Emergency Diesel Generator Operation 81

OP-1203.012A Annunciator K01 Corrective Actions 46

OP-2104.004 SDC System 64

OP-2104.005 Containment Spray 83

OP-2104.036 Emergency Diesel Generator Operations 98

Work Orders WO 261219, 395275, 461547, 511635, 521657, 522220, 524108,

24122, 52774476, 52796462, 52798635, 52805005,

2809497, 52810242, 52825505

71111.18 Calculations CALC-10-E-0010- ANO-1 HPI Rooms GOTHIC Heat-up Calculations 0

CALC-87-D-1016- Thermal and Hydraulic Calculation for Lube Oil Cooler E- 1

39A, E-39B, and E-39C

CALC-87-E-0011- Post LOCA HPI Temperature with No Room Cooling with 1

Two Trains of ECCS Available

CALC-92-R-2010- Non-Permanent Plant Equipment to Remain Inside the ANO- 8

2 Containment Building

Corrective Action CR-ANO- 1-2019-00879, 2-2018-04242, 2-2019-00701, 2-2019-00718,

Documents 2-2019-01219, 2-2019-01240, C-2019-01678

Drawings M-231 Sheet 1 P&ID Makeup and Purification System 116

M-232 Sheet 1 P&ID Decay Heat Removal System 108

Engineering EC-80852 High Pressure Injection Pump B Motor Replacement 0

Changes EC-82335 2P-32C Access Cover Temporary Enclosure 0

Procedures EN-QV-102 Quality Control Inspection Program 7

OP-1015.036 Containment Building Closeout 56

OP-1104.002 Makeup and Purification System Operation 95

OP-1104.004 Decay Heat Removal Operating Procedure 130

OP-1202.012 Repetitive Tasks 19

OP-1203.041 Small Break LOCA Cooldown 8

OP-1305.040 Service Water Flow Testing 1

Work Orders WO 521614, 52271362

71111.19 Corrective Action CR-ANO- 1-2019-00910, 2-2010-02863, 2-2010-02865, 2-2016-04277,

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents 2-2017-02269, 2-2019-00780, 2-2019-00856, 2-2019-00863,

2-2019-00935, 2-2019-00936, 2-2019-00937, 2-2019-00938,

2-2019-00944, 2-2019-00948, 2-2019-00949, 2-2019-00951,

2-2019-00952, 2-2019-00953, 2-2019-00954, 2-2019-00955,

2-2019-00956, 2-2019-00957, 2-2019-00958, 2-2019-00959,

2-2019-01084, 2-2019-01130

Corrective Action CR-ANO- 1-2019-00879, 2-2019-00863, 2-2019-01132, 2-2019-01171,

Documents 2-2019-01172

Resulting from

Inspection

Miscellaneous CEP-WP-004 Weld Map 7.4

ER 991782N201

ISO 2HBC-76-2

ISO 2HCC-313-1

MAI-21068

NDE 2-BOP-UT-

10-017

Tagout SW-082 Repair Leak

TD W180.0050 Instructions for Installing and Operation Seal Injection Water 2

Coolers

Procedures EN-WM-107 Post Maintenance Testing 5

OP-1104.002 Makeup and Purification System Operation 95

OP-1305.040 Service Water Flow Test 1

OP-1416.052 Unit 1 and 2 IAC66K Relay Test Instructions 7

OP-1416.064 Unit 1 and 2 HFC11B and HFC21B Relay Test Instructions 5

OP-2104.005 Containment Spray 83

OP-2104.036 EDG Ops 98

Work Orders WO 261219, 461547, 521657, 522220, 522780, 5280434,

271362, 52790576, 52798126, 52810242

71111.20 Corrective Action CR-ANO- 2-2019-01461, 2-2019-01462, 2-2019-01463, 2-2019-01464

Documents

Resulting from

Inspection

Engineering EC-83134 Engineering Evaluation 01: Acceptability of Rigging 2P-32B 0

Inspection Type Designation Description or Title Revision or

Procedure Date

Changes in Mode 5 and Deviations from EC53308 Requirements

EC-83154

Procedures EN-OU-108 Shutdown Safety Management Program 9

OP-1015.016 RCS/PZR Temperature vs Time 43

OP-2102.010 Plant Cooldown 59

OP-2104.004 Shutdown Cooling System 64

71111.22 Calculations CALC-91-R-2013- Service Water Performance Testing Methodology 29

CALC-92-E-0078- Unit 2 CSS Pump Performance Requirements 1

CALC-97-E-0020- Instrument Error Analysis for Containment Spray Pump 0

Local Indicators to Support Containment Spray Pump

Inservice Testing

CALC-97-E-0020- Loop Error Analysis for 2FT-5610 and 2FT-5616 to Support 1

Containment Spray Pump IST

Corrective Action CR-ANO- 1-2013-01728, 1-2014-01535, 1-2016-01004, 1-2019-00959,

Documents 1-2019-01125, 2-2011-01925, 2-2017-02189, 2-2017-03337,

2-2018-04357, 2-2019-00944, 2-2019-01264, C-2017-

01651, C-2017-01780

Corrective Action CR-ANO- 1-2019-01032, 1-2019-01035, 1-2019-01055, 2-2019-01478

Documents

Resulting from

Inspection

Drawings M-209, Sheet 1 P&ID Circulating Water, Service Water, and Fire Water 115

Intake Structure

Engineering EC-44915 CV-3640/3644 Valve Rotation 18 Degrees 0

Changes EC-75425 Documentation of Baseline for ANO-2 Reference Values for 0

IST

EC-77690 Document Analysis of 1R27 As-Found and As-Left Service 0

Water Flow Test per CALC-91-R-2013-01

EC-81619 Calculation Change Evaluation 0

Engineering ER-ANO-2005- Inservice Testing Acceptance Criteria for Unit 2 Containment 0

Evaluations 0072-000 Spray Pumps

Miscellaneous PIF 2-19-0049

Inspection Type Designation Description or Title Revision or

Procedure Date

SEP-ANO-2-IST- ANO Unit 2 Inservice Testing Bases Document 5

SEP-ANO-IST-2 ANO Unit 2 Inservice Testing Plan 5

SEP-ANO-IST-3 ANO Unit 2 Inservice Testing Cross Reference Document 5

STM-2-05 Emergency Core Cooling System 34

ULD-1-SYS-10 ANO Unit 1 Service Water System 17

Procedures OP-1015.001 Conduct of Operations 118

OP-1104.029 Service Water and Auxiliary Cooling System 119

OP-1104.036 Emergency Diesel Generator Operation 81

OP-2104.005 Containment Spray 83

OP-2104.040 LPSI System Operations 75

OP-2106.006 Emergency Feedwater System Operations 100

Work Orders WO 523470-01, 52704842-01, 52788661, 52794379, 52807284,

2820434, 52794842

71114.04 Miscellaneous 0CAN041901 Emergency Plan Revision 43, Arkansas Nuclear One - Units 04/04/2019

and 2, Docket Nos. 50-313, 50-368, and 72-13; Renewed

Facility Operating License Nos. DPR-51 and NPF-6

9.1, EC 71778, Super Particulate Iodine Noble Gas (SPING) 03/14/2018

Process Radiation Monitoring System Replacement Project,

Applicability Associated Child ECs 71779, 74229, 76289 and Field

Determination Change Request (FCR) Tracked by AR 283491

Form

9.2, Procedure/Document Number: EC74229, Revision: 0 09/20/2018

CFR

50.54(q)(3)

Screening

9.3, Procedure/Document Number: EC74229, Revision: 0 09/20/2018

CFR

50.54(q)(3)

Evaluation

9.3, Procedure/Document Number: EC 717778 and 71779, 10/03/2017

CFR Revision: 0

50.54(q)(3)

Inspection Type Designation Description or Title Revision or

Procedure Date

Evaluation

9.3, Procedure/Document Number: ANO Emergency Plan, 03/21/2019

CFR Revision: 43

50.54(q)(3)

Evaluation

Procedures EN-EP-305 Emergency Planning 10CFR50.54(q) Review Program 6

71114.06 Corrective Action CR-ANO- 1-2019-01245, 2-2019-01478

Documents

Resulting from

Inspection

Procedures OP-1202.002 Loss of Subcooling Margin 11

OP-1202.010 ESAS 12

OP-1203.039 Excess RCS Leakage 18

OP-1203.041 Small Break LOCA Cooldown 8

OP-1903.011 Emergency Response/Notifications 57

71124.02 Corrective Action CR-ANO- 1-2018-00306, 1-2018-01063, 2018-01273, 1-2018-01359,

Documents 1-2018-01840, 1-2018-02388, 1-2018-02484, 1-2018-03229,

1-2018-03492, 1-2018-03544, 1-2019-01039, 2-2017-06115,

2-2018-00740, 2-2018-00862, 2-2018-02545, 2-2018-03171,

2-2019-01128, C-2018-01264, C-2018-01465, C-2018-

01622, C-2018-02513, C-2018-02799, C-2018-04302, C-

2018-04354, C-2019-00313

Miscellaneous 1R26 ALARA Report 2016

1R27 ALARA Report 2018

2R25 ALARA Report 2017

2R26 ALARA Report 2018

ANO Alpha Hazard Evaluation 10/15/2018

ANO Full 5-Year Exposure Reduction Plan 2019-2023 12/11/2018

ANO-2018-0083 2018 Radiation Energy Distribution Evaluation 12/12/2018

Procedures EN-RP-100 Radiation Worker Expectations 12

EN-RP-102 Radiological Control 6

EN-RP-105 Radiological Work Permits 18

EN-RP-106 Radiological Survey Documentation 7

EN-RP-110 ALARA Program 14

Inspection Type Designation Description or Title Revision or

Procedure Date

EN-RP-110-01 ALARA Initiative Deferrals 1

EN-RP-110-03 Collective Radiation Exposure (CRE) Reduction Guidelines 4

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

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

EN-RP-121 Radioactive Material Control 15

EN-RP-121 Radioactive Material Control 15

Radiation Work 2016-1404 Routine Maintenance Activities During 1R26 (Bulk Work) 02

Permits (RWPs) 2017-2500 2E-35 A/B Replacement Activities During 2R25 02

2018-1401 Radiation Protection Activities 1R27 01

2018-1404 Maintenance Activities 1R27 (Bulk Work) 01

2018-1501 Replace Service Water Piping VCC-2 A/B to include both 02

locations

2018-2430 2R26 Reactor Disassembly/Re-Assembly 02

2018-2903 Inspections/Repair of Reactor Vessel Closure Head (RVCH) 01

Nozzle #49

2019-2057 U2 Reactor Building Power Entries for Surveys and Repairs 02

Related to 2P-32C ("C" Reactor Coolant Pump) Oil Leak

Self-Assessments ANO-2018-0010 ANO 2017 Annual Radiation Protection Report 01/30/2018

ANO-2019-0011 ANO 2018 Annual Radiation Protection Report 02/28/2019

LO-ALO-2018- Self-Assessment: Radiation Safety - ALARA & Dose 11/01/2018

00062-02 Assessment

71124.04 Corrective Action CR-ANO- 1-2018-02983, 2-2018-02350, 2-2018-03530, 2-2018-03816,

Documents C-2017-04510, C-2017-04582, C-2018-00617, C-2018-

00633, C-2018-01033, C-2018-01248, C-2018-02585, C-

2018-02587, C-2018-03632, C-2018-03925, C-2018-03926,

C-2018-04312, C-2018-04599, C-2019-00220, C-2019-

221, C-2019-00458, C-2019-00616, C-2019-00725, HQN-

2018-01384

Miscellaneous Aggregate DLR DDE / SRD Comparison Report 3/21/2019

2018 NVLAP Accreditation Certificate 1/1/2018

2019 NVLAP Accreditation Certificate 12/17/2018

ANO-2018-0015 2018 Neutron Dose Assignment Protocol 2/19/2018

ANO-2018-0079 2017-2018 ANO Evaluation of Internal Dose Monitoring 12/4/2018

Inspection Type Designation Description or Title Revision or

Procedure Date

C-2017-04510 Dosimetry Investigation Report ID 22453 11/28/2017

C-2017-04582 Dosimetry Investigation Report ID 20029 12/5/2017

C-2018-01248 Dosimetry Investigation Report ID 21535 3/14/2018

C-2018-01248 Dosimetry Investigation Report ID 21329 3/14/2018

EN-RPT-18-001- Standardization of a Bias between DLR and SRDs in the 9/25/2018

RO Entergy Fleet

Procedures 1000.031 Radiation Protection Manual 22

EN-RP-104 Personnel Contamination Events 11

EN-RP-201 Dosimetry Administration 5

EN-RP-202 Personnel Monitoring 13

EN-RP-203 Dose Assessment 10

EN-RP-204 Special Monitoring Requirements 11

EN-RP-204-01 Effective Dose Equivalent (EDEX) Monitoring 3

EN-RP-205 Prenatal Monitoring 3

EN-RP-206 Dosimeter of Legal Record Quality Assurance 6

EN-RP-208 Whole Body Counting / In-Vitro Bioassay 7

EN-RP-210 Area Monitoring Program 1

EN-RP-311 Electronic Alarming Dosimeters 2

Radiation Work 2018-1902 Diving Activities in Support of Fuel Transfer System Repair 01

Permits (RWPs) 2018-2056 U2 Containment Power Entries for Inspection & Minor 00

Maintenance

2018-2903 Inspections/Repair of Rx Vessel Closure Head (RVCH) 01

Nozzle #49

Self-Assessments ANO-2019-0011 Arkansas Nuclear One 2018 Annual Radiation Protection 2/28/2019

Report

LO-ALO-2018- Self-Assessment: Radiation Safety - ALARA & Dose 11/1/2018

00062-02 Assessment

71152 Corrective Action CR-ANO- 1-2019-00529, 1-2019-01181, 2-2019-01429, 2-2019-01430,

Documents 2-2019-01431, C-2019-00970, C-2019-01147, 2-2019-

01359, 2-2019-01432, 1-2019-01418, C-2019-02098, C-

2019-02144, 1-2018-05311, 2-2018-03018, C-2019-00649,

1-2019-01181

71153 CR-ANO- 1-2019-01181

Inspection Type Designation Description or Title Revision or

Procedure Date

Miscellaneous STM 1-66 Emergency Feedwater Initiation and Control 12

Procedures OP-1203.012K Annunciator K12 Corrective Action 50

OP-1304.206 Unit 1 EFIC Channel B Monthly Test, SG Pressure Greater 32

Than 750 psig

34