IR 05000313/2019002: Difference between revisions
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{{#Wiki_filter: | {{#Wiki_filter:ust 1, 2019 | ||
==SUBJECT:== | |||
ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000313/2019002 AND 05000368/2019002 | |||
- INTEGRATED INSPECTION REPORT 05000313/2019002 AND 05000368/2019002 | |||
==Dear Mr. Anderson:== | ==Dear Mr. Anderson:== | ||
On June 30, 2019 | 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. | ||
, 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. | |||
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 | 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. | ||
, DC 20555-0001; with copies to the Regional Administrator, Region IV | |||
. | |||
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= | =SUMMARY= | ||
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the | 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. | ||
. NRC and self-revealed findings and violations are summarized in the | |||
Failure to Perform Procedural Steps in Sequence during Surveillance Testing Cornerstone Significance Cross-Cutting Aspect | 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. | ||
-02 | |||
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. | |||
-1304.206, | |||
-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. | Additional Tracking Items None. | ||
=PLANT STATUS= | =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 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. | ||
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 | 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. | ||
-off lines. | |||
==INSPECTION SCOPES== | ==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 | 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. | ||
-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, | |||
-Water Reactor Inspection Program - Operations Phase. | |||
==REACTOR SAFETY== | ==REACTOR SAFETY== | ||
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===Impending Severe Weather Sample (IP Section 03.03)=== | ===Impending Severe Weather Sample (IP Section 03.03)=== | ||
{{IP sample|IP=IP 71111.01|count=1}} | {{IP sample|IP=IP 71111.01|count=1}} | ||
Unit 1 and Unit 2 Arkansas River flooding and potential severe weather on May 29, 2019. | Unit 1 and Unit 2 Arkansas River flooding and potential severe weather on May 29, 2019. | ||
Seasonal Extreme Weather Sample (IP Section 03.02) | 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) | 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== | ==71111.04 - Equipment Alignment== | ||
===Partial Walkdown Sample (IP Section 03.01) | ===Partial Walkdown Sample (IP Section 03.01)=== | ||
{{IP sample|IP=IP 71111.04|count=5}} | |||
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; | : (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, | : (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 | : (3) Unit 2 engineering safety feature room A, B, and C safety-related ventilation system on June 11, 2019; | ||
-related ventilation system on June 11, 2019; | |||
: (4) Unit 1 emergency diesel generator 2 exhaust fan D on June 18, 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. | : (5) Unit 2 control element assemblies operating on the lower gripper on June 28, 2019. | ||
71111.04S | ===71111.04S - Equipment Alignment Complete Walkdown Sample (IP Section 03.02) === | ||
- Equipment Alignment Complete Walkdown Sample (IP Section 03.02)=== | |||
{{IP sample|IP=IP 71111.04|count=1}} | {{IP sample|IP=IP 71111.04|count=1}} | ||
Unit 2 low pressure safety injection system on May 30, 2019. | Unit 2 low pressure safety injection system on May 30, 2019. | ||
Line 118: | Line 102: | ||
==71111.05Q - Fire Protection== | ==71111.05Q - Fire Protection== | ||
===Quarterly Inspection (IP Section 03.01) | ===Quarterly Inspection (IP Section 03.01)=== | ||
{{IP sample|IP=IP 71111.05Q|count=6}} | |||
: (1) Unit 1 radwaste processing area, Fire Zone 20 | |||
-Y, Fire Area C, on April 8, 2019; | The inspectors evaluated fire protection program implementation in the following selected areas: | ||
: (2) Unit 1 upper north piping penetration room, Fire | : (1) Unit 1 radwaste processing area, Fire Zone 20-Y, Fire Area C, on April 8, 2019; | ||
: (3) Unit 1 lab and demineralizer access area, Fire Area 67 | : (2) Unit 1 upper north piping penetration room, Fire Zone 79-U, Fire Area B-1, on April 11, 2019; | ||
-U, Fire Area B | : (3) Unit 1 lab and demineralizer access area, Fire Area 67-U, Fire Area B-9, on April 11, 2019; | ||
-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; | ||
: (4) Unit 2 engineering safety features Room A, Fire Zone 2014 | : (5) Unit 2 engineering safety features Room C, Fire Zone 2010-LL, Fire Area B-6, on May 15, 2019; | ||
-LL, Fire Area B | : (6) Unit 2 engineering safety features Room B, Fire Zone 2007-LL, Fire Area AA, on May 16, 2019. | ||
-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 | |||
==71111.06 - Flood Protection Measures== | ==71111.06 - Flood Protection Measures== | ||
Inspection Activities | ===Inspection Activities - Internal Flooding (IP Section 02.02a.)=== | ||
- Internal Flooding (IP Section 02.02a.)=== | {{IP sample|IP=IP 71111.06|count=1}} | ||
{{IP sample|IP=IP 71111. | |||
The inspectors evaluated internal flooding mitigation protections in the: | The inspectors evaluated internal flooding mitigation protections in the: | ||
Unit 1 breaching of train bay hatch HTC | Unit 1 breaching of train bay hatch HTC-492 in support of maintenance activities on April 22, 2019. | ||
-492 in support of maintenance activities on April 22, 2019. | |||
==71111.07A - Heat Sink Performance | ==71111.07A - Heat Sink Performance== | ||
===(1 | ===Annual Review (IP Section 02.01)=== | ||
{{IP sample|IP=IP 71111.07A|count=1}} | |||
The inspectors evaluated readiness and performance of: | |||
Unit 2 engineering safety features room A, B, and C room coolers on May 30, 2019. | 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== | ==71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance== | ||
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) | ===Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)=== | ||
{{IP sample|IP=IP 71111.11Q|count=2}} | |||
: (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; | : (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 | : (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)=== | Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)=== | ||
Unit 1 licensed operator requalification scenario on April 16, 2019. | Unit 1 licensed operator requalification scenario on April 16, 2019. | ||
==71111.12 - Maintenance Effectiveness== | =====71111.12 - Maintenance Effectiveness== | ||
===Quality Control (IP Section 02.02) | ===Quality Control (IP Section 02.02)=== | ||
{{IP sample|IP=IP 71111.12|count=2}} | |||
: (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; | 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. | : (2) Unit 1 high pressure injection pump motors on May 30, 2019. | ||
Routine Maintenance Effectiveness Inspection (IP Section 02.01)=== | Routine Maintenance Effectiveness Inspection (IP Section 02.01) (1 Sample)=== | ||
The inspectors evaluated the effectiveness of routine maintenance activities associated with | |||
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions: | |||
===the following equipment and/or safety significant functions: | |||
Unit 2 low pressure safety injection system on May 17, 2019. | Unit 2 low pressure safety injection system on May 17, 2019. | ||
==71111.13 - Maintenance Risk Assessments and Emergent Work Control== | ==71111.13 - Maintenance Risk Assessments and Emergent Work Control== | ||
===Risk Assessment and Management Sample (IP Section 03.01) | ===Risk Assessment and Management Sample (IP Section 03.01)=== | ||
{{IP sample|IP=IP 71111.13|count=6}} | |||
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; | : (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; | : (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; | ||
Line 185: | Line 169: | ||
==71111.15 - Operability Determinations and Functionality Assessments== | ==71111.15 - Operability Determinations and Functionality Assessments== | ||
Operability Determination or Functionality Assessment (IP Section 02.02) | ===Operability Determination or Functionality Assessment (IP Section 02.02)=== | ||
{{IP sample|IP=IP 71111.15|count=7}} | |||
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; | : (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; | : (2) Unit 1 high pressure injection pump C and reactor building spray pump B elevated pump vibrations operability on April 9, 2019; | ||
Line 192: | Line 178: | ||
: (4) Unit 1 train B emergency diesel generator fan coil D temperature limit instrument drift operability on May 2, 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; | : (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; | : (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. | : (7) Unit 2 control element assemblies operating on the lower gripper drop time testing operability on June 28, 2019. | ||
==71111.18 - Plant Modifications== | ==71111.18 - Plant Modifications== | ||
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) | ===Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)=== | ||
{{IP sample|IP=IP 71111.18|count=2}} | |||
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; | : (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. | : (2) Unit 1 permanent modification of high pressure injection pump B motor replacement on May 28, 2019. | ||
Line 204: | Line 192: | ||
==71111.19 - Post-Maintenance Testing== | ==71111.19 - Post-Maintenance Testing== | ||
Post Maintenance Test Sample (IP Section 03.01) | ===Post Maintenance Test Sample (IP Section 03.01)=== | ||
{{IP sample|IP=IP 71111.19|count=8}} | |||
The inspectors evaluated the following post maintenance tests: | |||
: (1) Unit 1 reactor building spray pump A motor balancing maintenance on April 16, 2019; | : (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; | : (2) Unit 2 train B service water piping return header from emergency control room chiller B weld repair on April 22, 2019; | ||
Line 213: | Line 203: | ||
: (6) Unit 2 containment spray pump A motor preventive maintenance on April 30, 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; | : (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 | : (8) Unit 2 containment spray pump A breaker 2A-304 protective relay preventive maintenance on May 1, 2019. | ||
-304 protective relay preventive maintenance on May 1, 2019. | |||
==71111.20 - Refueling and Other Outage Activities== | ==71111.20 - Refueling and Other Outage Activities== | ||
Refueling/Other Outage Sample (IP Section 03.01) | ===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. | |||
-01 activities from May 26 to June 30, 2019. The inspectors completed inspection procedure Sections 03.01.a | |||
==71111.22 - Surveillance Testing== | ==71111.22 - Surveillance Testing== | ||
Line 226: | Line 214: | ||
The inspectors evaluated the following surveillance tests: | The inspectors evaluated the following surveillance tests: | ||
Inservice Testing (IP Section 03.01)=== | Inservice Testing (IP Section 03.01)=== | ||
{{IP sample|IP=IP 71111. | {{IP sample|IP=IP 71111.20|count=1}} | ||
Unit 2 low pressure safety injection pump A inservice testing surveillance on April 5, 2019. | Unit 2 low pressure safety injection pump A inservice testing surveillance on April 5, 2019. | ||
Surveillance Tests (other) (IP Section 03.01) | Surveillance Tests (other) (IP Section 03.01) (5 Samples)=== | ||
: (1) Unit 2 train A low pressure safety injection and refueling water tank valve stroke | |||
: (1) Unit 2 train A low pressure safety injection and refueling water tank valve stroke surveillance on April 5, 2019; | |||
===surveillance on April 5, 2019; | |||
: (2) Unit 2 containment spray pump A surveillance testing on May 8, 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; | : (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 | : (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; | ||
-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. | : (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== | ==71114.04 - Emergency Action Level and Emergency Plan Changes== | ||
===Inspection Review (IP Section 02.01 | ===Inspection Review (IP Section 02.01-02.03)=== | ||
-02.03)=== | |||
{{IP sample|IP=IP 71114.04|count=1}} | {{IP sample|IP=IP 71114.04|count=1}} | ||
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. | 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== | ==71114.06 - Drill Evaluation== | ||
Line 251: | Line 238: | ||
===Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)=== | ===Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)=== | ||
{{IP sample|IP=IP 71114.06|count=1}} | {{IP sample|IP=IP 71114.06|count=1}} | ||
Unit 1 loss of coolant accident concurrent with a loss of offsite power with multiple equipment failures on May 15, 2019. | Unit 1 loss of coolant accident concurrent with a loss of offsite power with multiple equipment failures on May 15, 2019. | ||
Line 259: | Line 247: | ||
===Radiological Work Planning (IP Section 02.01)=== | ===Radiological Work Planning (IP Section 02.01)=== | ||
{{IP sample|IP=IP 71124.02|count=1}} | {{IP sample|IP=IP 71124.02|count=1}} | ||
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: | |||
==2R25 | * 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== | ==71124.04 - Occupational Dose Assessment== | ||
Line 287: | Line 276: | ||
===External Dosimetry (IP Section 02.02)=== | ===External Dosimetry (IP Section 02.02)=== | ||
{{IP sample|IP=IP 71124.04|count=1}} | {{IP sample|IP=IP 71124.04|count=1}} | ||
The inspectors evaluated the external dosimetry program implementation. | The inspectors evaluated the external dosimetry program implementation. | ||
Internal Dosimetry (IP Section 02.03) | Internal Dosimetry (IP Section 02.03) (1 Sample)=== | ||
The inspectors evaluated the internal dosimetry program implementation. | |||
===Whole Body Counts ID Date 1. | |||
===23721 11/14/2018 2. | |||
23089 10/20/2018 3. | |||
20639 3/28/2018 4. | |||
23799 10/19/2018 5. | |||
24295 5/5/2018 In-vitro internal monitoring ID Date Sample No. | |||
1. | |||
24610 4/5/2018 FIS 2499 2. | |||
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) === | |||
{{IP sample|IP=IP 23721|count=1}} | |||
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 1. | |||
===21082 10/27/2018 2. | |||
23810 10/27/2018 EDEX exposures: | |||
ID Date 1. | |||
24625 10/13/2019 2. | |||
24628 10/13/2019 Shallow Dose Equivalent: | |||
ID Date Assessment No. | |||
: | |||
1. | |||
24458 10/19/2018 2018-057 2. | |||
24309 10/25/2018 2018-064 Neutron Dose Assessment: | |||
ID Date 1. | |||
29595 2H18 2. | |||
21914 2H18 | |||
The licensee | ==OTHER ACTIVITIES - BASELINE== | ||
71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below: | |||
1 | BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) | ||
=== | |||
{{IP sample|IP=IP 21082|count=2}} | |||
: (1) Unit 1 (April 1, 2018 - March 31, 2019); | |||
: (2) Unit 2 (April 1, 2018 - March 31, 2019). | |||
2 | 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)=== | ||
{{IP sample|IP=IP 71152|count=1}} | |||
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) === | ||
{{IP sample|IP=IP 71153|count=2}} | |||
: (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, 2019. | |||
This | ==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. | |||
- | |||
- | |||
Condition | 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. | ||
-ANO- | |||
- | |||
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 | 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=== | |||
-ANO- | |||
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. | |||
-related | |||
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. | |||
Specifically, temperature switch TS | 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. | ||
-7904 | |||
=====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 | 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. | |||
-of- | * 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. | |||
-7904 | |||
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 | 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 hours. | |||
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:===== | |||
-OP-104 | 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. | |||
This condition resulted in the licensee declaring EDG 2 as operable | 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. | ||
-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: | Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy. | ||
-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 Aspect | 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. | ||
-02 | |||
-revealed, Green finding and associated non | |||
-cited violation of Arkansas Nuclear One Unit 1, Technical Specification 5.4.1.a, for the | |||
-1304.206, | |||
-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:===== | =====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. | 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. | |||
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: | 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. | * 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 | 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. | |||
The licensee | 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. | |||
Enforcement Action: | |||
-cited violation, consistent with Section 2.3.2 of the Enforcement Policy. | |||
==EXIT MEETINGS AND DEBRIEFS== | ==EXIT MEETINGS AND DEBRIEFS== | ||
The inspectors verified no proprietary information was retained or documented in this report. | 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 9, 2019 | * 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. | ||
, the | * 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. | ||
, and other members of the licensee staff. | |||
On May 15, 2019 | |||
, the | |||
-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= | =DOCUMENTS REVIEWED= | ||
Inspection | Inspection Type Designation Description or Title Revision or | ||
Description or Title | Procedure Date | ||
Revision or Date 71111.01 Calculations | 71111.01 Calculations CALC-92-E-0078- LPSI Pump NPSH Calculation 0 | ||
CALC-92-E-0078- | Corrective Action CR-ANO- 1-2018-04294, 1-2019-00959, 1-2019-01061, 1-2019-01032, | ||
Corrective Action | Documents 1-2019-01033, C-2019-01992, C-2019-01993 | ||
CR-ANO- 1-2019-01036, C-2019-01552 | Corrective Action CR-ANO- 1-2019-01036, C-2019-01552 | ||
-Segregated Bus Duct Flood Modification | Documents | ||
Procedures | Resulting from | ||
OP-1015.033 ANO Switchyard and Transformer Yard Controls | Inspection | ||
OP-1106.006 Emergency Feedwater Pump Operation | 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-1203.007 Abnormal ES Bus Voltage and Degraded Offsite Power | OP-1106.006 Emergency Feedwater Pump Operation 109 | ||
OP-1203.025 Natural Emergencies | OP-1107.001 Electric System Operations 123 | ||
OP-1203.12H Annunciator K09 Corrective Action | OP-1202.007 Degraded Power 15 | ||
OP-2017.001 Electrical System Operations | OP-1203.007 Abnormal ES Bus Voltage and Degraded Offsite Power 14 | ||
OP-1203.025 Natural Emergencies 68 | |||
OP-2106.006 Emergency Feedwater System Operations | OP-1203.12H Annunciator K09 Corrective Action 50 | ||
OP-2017.001 Electrical System Operations 129 | |||
OP-2203.012F Annunciator 2K06 Corrective Action | OP-2104.005 Containment Spray 83 | ||
OP-2203.054 Abnormal Grid | OP-2106.006 Emergency Feedwater System Operations 100 | ||
Work Orders | OP-2203.008 Natural Emergencies 49 | ||
WO 525596, 516790 | OP-2203.012F Annunciator 2K06 Corrective Action 40 | ||
-15, 523470 | OP-2203.054 Abnormal Grid 2 | ||
-01 | Work Orders WO 525596, 516790-15, 523470-01 | ||
CALC-88-E-0032- | 71111.04 Calculations CALC-88-E-0032- LOCA Containment Analysis for ANO-2 SGR and Power 0 | ||
-2 SGR and Power Uprate | Uprate | ||
CALC-94-0094- | 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 | |||
CALC-94-E-0095- | |||
Inspection | Inspection Type Designation Description or Title Revision or | ||
Description or Title | Procedure Date | ||
Revision or Date Evaluation | 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 | |||
CR-ANO- 1-2019- | 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 | |||
EN- | OP-2203.012E Annunciator 2K05 Corrective Action 41 | ||
EN- | 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 | |||
ANO- | 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- | |||
3 | Documents 01929, C-2019-00241, C-2019-00252, C-2019-01773, C- | ||
2019-01976 | |||
Corrective Action CR-ANO- C-2019-00621 | |||
ANO-2018- | Documents | ||
2 | Resulting from | ||
2 | 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 | |||
2 | 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 | |||
}} | }} |
Revision as of 12:40, 19 October 2019
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.
REACTOR SAFETY
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, 2019.
RADIATION SAFETY
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 2018-1404, Maintenance Activities 1R27 (Bulk Work);
- RWP 2018-2430, 2R26 Reactor Disassembly/Reassembly;
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 2018-1404, Maintenance Activities 1R27 (Bulk Work);
- RWP 2018-2430, 2R26 Reactor Disassembly/Reassembly;
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 1.
===23721 11/14/2018 2.
23089 10/20/2018 3.
20639 3/28/2018 4.
23799 10/19/2018 5.
24295 5/5/2018 In-vitro internal monitoring ID Date Sample No.
1.
24610 4/5/2018 FIS 2499 2.
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 1.
===21082 10/27/2018 2.
23810 10/27/2018 EDEX exposures:
ID Date 1.
24625 10/13/2019 2.
24628 10/13/2019 Shallow Dose Equivalent:
ID Date Assessment No.
1.
24458 10/19/2018 2018-057 2.
24309 10/25/2018 2018-064 Neutron Dose Assessment:
ID Date 1.
29595 2H18 2.
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, 2019.
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:
- 8.8.8 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;
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
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
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
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
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
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