IR 05000313/1997014

Discusses Predecisional Enforcement Conference Conducted to Discuss Violations Noted in Insp Repts 50-313/97-14 & 50-368/97-14.Violations Noted:Failure to Comply w/10CFR50, App B,Criterion IX & Failure to Remove Unit 2 from Svc

ML20199C486
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/18/1997
From:	Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Hutchinson C ENTERGY OPERATIONS, INC.
Shared Package
ML20199C490	List: ML20199C486 ML20199C517
References
50-313-97-14, 50-368-97-14, EA-97-382, NUDOCS 9711200032
Download: ML20199C486 (5)

Text

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%. 4, * * * * * ,0 AR LINoTON, T EXAS 760108064 November 18, 1997 EA 97-382 C. Randy Hutchinson, Vice President Operations Arkansas Nuclear One Entergy Operations, Inc.

1448 S.R. 333 Russellville, Arkansas 72801-0967 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-313/97-14; 50-368/97-14)

Dear Mr. Hutchinson:

This is in reference to the predecisional enforcement conference held in the NRC's Arlington, Texas office on September 26,1997. The conference was conducted to discuss three apparent violations of NRC requirements related to inspections of steam generator tubes at Arkansas Nuclear One, Units 1 and 2. The results of our inspection were discussed with your staff during a telephonic exit briefing conducted on August 8,1997, and were documented in the subject NRC Inspection Report, which was issued September 12,1997.

After the September 26 conference, ANO provided further information and clarification during a telephone discussion held on October 2,1997.

The three apparent violations described in the inspection report involved: (1) a failure to comply with 10 CFR Part 50 Appendix B Criterion IX in the use of data in bobbin coil sizing qualification criteria that did not conform to the requirements of the selected qualification method; (2) the failure to remove Unit 2 tubes from service which contained flaws that exceeded the plugging limit of the Technical Specifications; and (3) the lac!; of prompt corrective action in November 1995 prior to-retuming potentially defective sleeved tubes to service.

During the September 26 conference, Enter'g y expressed disagreement with the first apparent violation, contending that Entergy's sizing qualification for intergranular attack (IGA) met the provisions of appropriate industry qualification processes (EPRI Appendix "H"), and therefore Entergy was in compliance with 10 CFR Part 50 Appendix B. With regard to the second _

apparent violation, which involved Unit 2 steam generators, Entergy agreed that the violation occurred but contended that the violation warranted treatment as a non-cited violation.

Entergy also disputed the third apparent violation, which is discussed below.

The NRC considered Entergy's arguments and has concluded that vic;dions of NRC requirements occurred.

Based on the discussions The at the violations conference, weare cited have in the modified the enclosed first violationNotice to stateof Violation (No that 7 Entergy's inservice inspections of Unit 1 steam generators were not appropriately controlled g

, and accumplished to identify tube defects that exceeded the technical specification plugging (f 9711200032 971118 i

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Entergy Operations, Inc. -2-limit. The second violation involves Unit 2 steam generator tubes, with defects greater than

' the technical specification plugging limit, that were improperly considered operable.

Although these violations involve steam generators of different designs and different IGA flaw sizing methodologies, the violations are similar in that your methods for sizing lGA and tubing degradation in both Units 1 and 2 steam generators were shown to have been inadequate.

The actual safety consequence of these violations is low because no significant leakage occurred as a re: ult of tube leaks. These issues are of regulatory significance because of the programmatic nature of the problem; that is, you relied on methods which were incapable of detecting flaws greater than the plugging limit, and as a result, operated Units 1 and 2 with steam generators with tubes containing flaws that exceeded the technical specification plugging limit of 40 percent through wall (TW). Therefore, these two violations have been categorized in the aggregate in accordance with the " General Statement of Policy and Procedure for WRC Enforcement Actions"(Enforcement Policy), NUREG-1600, as a Severity Level lli problem.

In accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000 is considered for a Severity Level 111 problem. Because your facility has been the subject of escalated enforcement actions within the last 2 years', the NRC considered whether credit was warranted for Identification and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. Since Entergy identified both issues, the NRC has determined that Entergy is deserving of identification credit.

Further, the NRC has determined that Entergy is deserving of Corrective Action credit.

Entergy's corrective actions for the first violation included declaring the steam generators inoperable, notifying the NRC, requesting (and being granted) a Notice of Enforcement Discretion from the NRC, administratively precluding IGA sizing, and investigating the cause of the problem. Entergy's corrective actions to the second violation included reviewing more

"no detectable degradation" determinations to verify the quality of the 2R12 analyses, performing enhanced inservice inspectio".s of indications, repairing the eggerate cracks, enhancing training, and providing additional oversight of the inservice inspections.

Therefore, to encourage prompt identification and comprehensive correction of violations, I have been authorized not to propcse a civil penalty in this case. However, significant violations in the future could result in a civi! penalty.

The third violation cited in the enclosed notice involves Entergy's failure to take prompt corrective actions prior to retuming to service potentially defective sleeved tubes exhibiting weld zone eddy current indications. At the conference, Entergy representatives expressed disagreement with this violation, contending that sufficient technical basis existed (including

' A Severity Level 111 problem and a $50,000 civil penalty was issued on April 9,1997, involving fire protection inadequacies and the plant staff's inadequate response to ind:ations of a fire (EA 96-512).

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Entergy Operations, Inc. 3 ultrasonic testing and visual testing) to justify use of the sleeves as-is. Further, Entergy representatives noted thet, after re-inspection, only one of 28 indications was identified for repair based on new acceptance criteria and that all 28 indications met structural and leakage requirements; Notwithstanding Entergy's argument that the structural integrity of the sleeves was maintained, the NRC's position is that Entergy had an indication of a condition adverse _to quality, and it took inadequate corrective actions. Specifically, your actions (in October 1995, during 2R11) were not adequate to evaluate defects that existed at the time, nor did you perform an operabrity assessment at the time. Therefore, in accordance with the its Enforcement Policy, the NRC has classified this violation et Severity Leve,l IV.-

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

encksed Notice when preparing your response in your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. The NRC will use your response, in part, to deteimine whether further enforcement action is necessary to ensure compliance with regulatory requirements, in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosure, arid your response will be placed in the NRC Public Document Room (POR).

Sincerely,

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Ellic W. Mers Regional Adm'iistrator Dockets: 50-313-50-368 Licenses: DPR 51 NPF-6

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cc w/ Enclosure:

Executive Vice President

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Entergy Operations, Inc.

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P.O. Box 31995 L Jackson, Mississippi 39286-1995

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Vice President Operations Support Entergy Operations, Inc.

P.O. Box 31995 Jackson, Mississippl 39286-Manager, Washington Nuclear Operations ABB Combustion Engineering Nuclear

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Power 12300 Twinbrook Parkway, Suite 330 <

Rockville, Maryland 20852 County Judge of Pope County Pope County Courthouse Russellville, Arkansas : 72801 Winston & Strawn -

1400 L Street, N.W.

WasNngton, D.C. 20005 3502 David D. Snellings, Jr., Director Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street, Mail Slot 30 Little Rock, Arkansas 72205-3867 Manager Rockville Nuclear Licensing '

Framatome Technologies 1700 Rockville Pike, Suite 525 Rockville, Maryland 20852

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SECY EC's: Rl,Ril,Rlli CA PA (Os2G4)

EDO (017G21) OiG (T 5D28)

DEDO (0-17G21) OE (0 7H5)

OE:EAFile (0 7H5) 01 (0 3E4)

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OGC (0-15818) OGC (015B18)

NRR (012G18) NRR/ADP (012G18)

NRR PROJECT MANAGER OC/DAF (T-9E10)

OC/LFDCS (T 9E10) AEOD (T-4D18)

RA Reading File GSanborn-EAFile RWise (if app.) RWise-DOL File (if app.)

RIV Files MIS Coordinator ECollins, RIV E Mall DlHTRIBUTION:

OEMAIL: JDyer (JED2)

TPGwynn (TPG) WBrown (WLB)

GSanborn (GFS) GMVasquez (GMV)

BHenderson (BWH) MHammond (MFH2)

CHackney (CAH) DKunihiro (DMK1)

Art Howell (ATH) DChamberlain (DDC)

KPerkins (KEP) ECollins (EEC)

SENIOR RESIDENT- KBrockman (KEB)

EMerschoff (EWM)

DOCUMENT NAME: G:\EA\ DRAFT \EA97382.DFT To receive, copy opument, Indicats in box: "C" = Copy wthout oncesures "E" = Copy with enclosures *N" = No copy

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