ML15218A371

IR 05000313/2015002; 05000368/2015002; on 04/01/2015 - 06/30/2015; Arkansas Nuclear One, Units 1 and 2, Integrated Inspection Report; Adverse Weather Protection, Flood Protection Measures, Inservice Inspection Activities

ML15218A371
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/05/2015
From:	O'Keefe N NRC/RGN-IV/DRP/RPB-E
To:	Jeremy G. Browning Entergy Operations
NEIL O'KEEFE
References
IR 2015002
Download: ML15218A371 (43)

See also: IR 05000313/2015002

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD.

ARLINGTON, TX 76011-4511

August 5, 2015

Mr. Jeremy Browning, Site Vice President

Arkansas Nuclear One

Entergy Operations, Inc.

1448 SR 333

Russellville, AR 72802-0967

SUBJECT: ARKANSAS NUCLEAR ONE - NRC INSPECTION REPORT 05000313/2015002

and 05000368/2015002

Dear Mr. Browning:

On June 30, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at

your Arkansas Nuclear One facility, Units 1 and 2. On July 9, 2015, the NRC inspectors

discussed the results of this inspection with you and other members of your staff. Inspectors

documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented four findings of very low safety significance (Green) in this report.

Three of these findings involved violations of NRC requirements. The NRC is treating these

violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC

Enforcement Policy.

If you contest the violations or significance of these NCVs, 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,

U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident

inspector at Arkansas Nuclear One.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a

regulatory requirement 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 Regional Administrator,

Region IV; and the NRC resident inspector at Arkansas Nuclear One.

On July 1, 2015, the NRC completed a quarterly performance review of Arkansas Nuclear One.

The NRC determined that continued plant operation was acceptable and oversight in the

Multiple/Repetitive Degraded Cornerstone of the Reactor Oversight Process Action Matrix

remained appropriate.

J. Browning -2-

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public

Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your

response (if any) will be available electronically for public inspection in the NRCs Public

Document Room or from the Publicly Available Records (PARS) component of the NRC's

Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible

from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic

Reading Room).

Sincerely,

/RA/

Neil OKeefe, Chief

Project Branch E

Division of Reactor Projects

Docket Nos. 50-313, 50-368

License Nos. DRP-51; and NPF-6

Enclosure: Inspection Report 05000313/2015002 and

05000368/2015002

w/ Attachment:

1. Supplemental Information

2. Detailed Risk Evaluation

cc w/ encl: Electronic Distribution

J. Browning -2-

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public

Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your

response (if any) will be available electronically for public inspection in the NRCs Public

Document Room or from the Publicly Available Records (PARS) component of the NRC's

Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible

from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic

Reading Room).

Sincerely,

/RA/

Neil OKeefe, Chief

Project Branch E

Division of Reactor Projects

Docket Nos. 50-313, 50-368

License Nos. DRP-51; and NPF-6

Enclosure: Inspection Report 05000313/2015002 and

05000368/2015002

w/ Attachment:

1. Supplemental Information

2. Detailed Risk Evaluation

DISTRIBUTION:

See next page

ADAMS Accession No.: ML#15218A371

SUNSI Review ADAMS Non- Publicly Available

By: NOKeefe Yes No Sensitive Non-Publicly Available

Sensitive

OFFICE SRI:DRP/E RI:DRP/E RE:DRS/EB1 DRS/OB DRS/PSB1

NAME BTindell MYoung MWilliams VGaddy MHaire

SIGNATURE /RA/ /RA/ /RA/ /RA/ /RAJLarsen for/

DATE 7/31/15 7/27/15 7/27/15 7/27/15 7/27/15

OFFICE DRP/PBE DRP/PBC DRS/EB1 DRP/PBE BC:DRP/E

NAME HGepford ERuesch TFarnholtz GPick NOKeefe

SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/

DATE 7/23/15 7/27/15 7/23/15 7/27/15 8/5/15

Letter to Jeremy Browning from Neil OKeefe dated August 5, 2015

SUBJECT: ARKANSAS NUCLEAR ONE - NRC INSPECTION REPORT

05000313/2015002 and 05000368/2015002

DISTRIBUTION:

Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)

DRP Director (Troy.Pruett@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

DRP Deputy Director (Ryan.Lantz@nrc.gov)

Senior Resident Inspector (Brian.Tindell@nrc.gov)

Resident Inspector (Matt.Young@nrc.gov)

Resident Inspector (Margaret.Tobin@nrc.gov)

Branch Chief, DRP/E (Neil.OKeefe@nrc.gov)

Senior Project Engineer, DRP/E (Nick.Taylor@nrc.gov)

Project Engineer, DRP/E (Thomas.Farina@nrc.gov)

Project Engineer, DRP/E (Brian.Correll@nrc.gov)

Project Engineer, DRP/E (Jackson.Choate@nrc.gov)

ANO Administrative Assistant (Gloria.Hatfield@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Andrea.George@nrc.gov)

Team Leader, DRS/TSS (Don.Allen@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov)

RIV/ETA: OEDO (Cindy.Rosales-Cooper@nrc.gov)

ROPreports

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000313; 05000368

License: DPR-51; NPF-6

Report: 05000313/2015002; 05000368/2015002

Licensee: Entergy Operations Inc.

Facility: Arkansas Nuclear One, Units 1 and 2

Location: Junction of Hwy. 64 West and Hwy. 333 South

Russellville, Arkansas

Dates: April 1 through June 30, 2015

Inspectors: B. Tindell, Senior Resident Inspector

M. Young, Resident Inspector

L. Carson, II, Senior Health Physicist

J. Drake, Senior Reactor Inspector

Z. Hollcraft, Reactor Operations Engineer

M. Phalen, Senior Health Physicist

M. Williams, Reactor Inspector

Approved Neil OKeefe

By: Chief, Project Branch E

Division of Reactor Projects

-1- Enclosure

SUMMARY

IR 05000313/2015002; 05000368/2015002; 04/01/2015 - 06/30/2015; Arkansas Nuclear One,

Units 1 and 2, Integrated Inspection Report; Adverse Weather Protection, Flood Protection

Measures, Inservice Inspection Activities.

The inspection activities described in this report were performed between April 1, 2015, and

June 30, 2015, by the resident inspectors at Arkansas Nuclear One and inspectors from the

NRCs Region IV office and other NRC offices. Four findings of very low safety significance

(Green) are documented in this report. Three of these findings involved violations of NRC

requirements. The significance of inspection findings is indicated by their color (Green, White,

Yellow, or Red), which is determined using Inspection Manual Chapter 0609, Significance

Determination Process. Their cross-cutting aspects are determined using Inspection Manual

Chapter 0310, Aspects within the Cross-Cutting Areas. Violations of NRC requirements are

dispositioned in accordance with the NRC Enforcement Policy. The NRCs program for

overseeing the safe operation of commercial nuclear power reactors is described in

NUREG-1649, Reactor Oversight Process.

Cornerstone: Initiating Events

• Green. The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B,

Criterion V, Instructions, Procedures, & Drawings, for the failure to establish appropriate

procedures for preparations for severe weather. Specifically, inspectors observed that the

licensee failed to ensure that all outside areas were inspected in order to secure material

prior to severe weather, to reduce the probability of light material missile damage on plant

equipment. The licensee concluded that the assignment of responsibilities was unclear in

Procedure EN-FAP-EP-010, Severe Weather Response, Revision 1, leading to confusion

among the two operating crews. This issue was entered into the licensees corrective action

program as Condition Reports CR-ANO-C-2015-00854 and CR-ANO-C-2015-00859.

The failure to have a procedure to ensure that all outside areas would be inspected in order

to secure loose material prior to the arrival of severe weather, to reduce the probability of

light material missile damage on plant equipment was a performance deficiency. The

performance deficiency was more than minor because it was associated with the procedure

quality attribute of the Initiating Events Cornerstone and adversely affected the cornerstone

objective to limit the likelihood of events that upset plant stability and challenge critical safety

functions during shutdown as well as power operations. Specifically, during severe weather,

unsecured material could become a missile that impacts equipment and upsets plant

stability. Using NRC Inspection Manual Chapter 0609, Appendix A, The Significance

Determination Process (SDP) for Findings At-Power, the inspectors determined that the

finding had very low safety significance (Green) because it did not represent an actual

reactor trip and the loss of mitigation equipment. This finding has a human performance

crosscutting aspect associated with work management, in that the organization failed to

implement a process of planning, controlling, and executing work activities, including

coordination with different groups or job activities. Specifically, only one crew performed the

required inspections when severe weather had been forecast since the procedure in use did

not clearly assign responsibilities to both operating crews [H.5]. (Section 1R01)

• Green. The inspectors reviewed a self-revealing finding involving failure to verify that the

proper material was installed in the plant during initial construction of the Unit 2 reactor

coolant system (RCS) sample system. Specifically, failure to use the correct material

-2-

resulted in two through-wall leaks in the supply line to the 2E30 cooler for the RCS sample

system. The licensee removed the components with the incorrect material and installed

components of the correct material. This issue was entered into the licensees corrective

action program as Condition Report CR-ANO-C-2014-01800.

The failure to verify the correct materials were installed in the plant is a performance

deficiency. This performance deficiency is more than minor because it is associated with

the equipment performance attribute of the Initiating Events Cornerstone and affects the

cornerstone objective to limit the likelihood of events that upset plant stability and challenge

critical safety functions during shutdown as well as during power operations. Specifically,

failure to install the correct material resulted in failure of the RCS sample system and the

inability to meet technical specification requirements for determining dose equivalent Xenon-

133. Using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 1, Initiating Event

Screening Questions, the inspectors determined the finding is of very low safety

significance (Green) because the transient initiator did not cause a reactor trip and the loss

of mitigating equipment. This finding has not been assigned a cross cutting aspect because

the incorrect material was installed during initial construction, and is not indicative of current

plant performance. (Section 1R08.1)

Cornerstone: Mitigating Systems

• Green. The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix

B, Criterion III, Design Control, for the failure to select and review equipment for suitability

of application that is essential to the safety-related function of Unit 2 motor control center

(MCC) 2B-52. Specifically, the licensee failed to ensure that the safety-related electrical

equipment inside the MCC was adequately protected from water spray in the event of a

failure of overhead non-seismic category 1 pipes, in accordance with the safety analysis

report. Inspectors identified that the installed spray curtain only protected the front of the

cabinet, while a cooling water pipe that could break during a seismic event was located

directly above the length of the MCC. This issue was entered into the licensees corrective

action program as Condition Report CR-ANO-C-2015-01342.

The failure to protect Unit 2 MCC 2B-52 from possible spray of overhead non-seismic

category 1 pipes by installing a spray shield in accordance with the safety analysis report

was a performance deficiency. The performance deficiency was more than minor because it

was associated with the design control attribute of the Mitigating Systems Cornerstone and

adversely affected the cornerstone objective to ensure the reliability of systems that respond

to initiating events to prevent undesirable consequences. Specifically, the performance

deficiency could result in failure of one train of essential safety features during a seismic

event, such as exhaust fans for the emergency diesel generators, containment spray

isolation valves, and high pressure safety injection isolation valves. Using NRC Inspection

Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for

Findings At-Power, the inspectors determined to require a detailed risk evaluation because

the finding involved degradation of equipment specifically designed to mitigate a seismic

event and could degrade one train of a system that supports a risk significant function. A

senior reactor analyst performed the detailed risk evaluation and estimated the change to

the core damage frequency was 3.8E-8/year (Green). The dominant core damage

sequences included seismically induced losses of offsite power. This finding did not have a

cross-cutting aspect associated with it because the most significant contributing cause was

not indicative of present performance. Specifically, the condition had existed since plant

construction, with no recent substantial opportunities to identify the issue. (Section 1R06)

-3-

• Green. The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B,

Criterion XI, Test Control, for the licensees failure to establish and maintain an adequate

testing program for the fuel oil transfer piping for Units 1 and 2. Specifically, the licensee did

not establish inservice testing to detect degradation of the fuel oil piping between the fuel oil

storage tanks and the emergency diesel generator day tanks. This issue was entered into

the licensees corrective action program as Condition Report CR-ANO-2-2015-01092.

The failure to perform the required testing of the fuel oil piping is a performance deficiency.

The performance deficiency is more than minor because it is associated with the protection

against external factors attribute of the Mitigating Systems Cornerstone, and affects the

cornerstone objective to ensure availability, reliability, and capability of systems that respond

to initiating events to prevent undesirable consequence. Specifically, the licensee failed to

perform examinations required to provide reasonable assurance that the piping could

perform its intended function during design basis seismic events, and therefore maintain the

ability to supply fuel to the emergency diesel generators. Using NRC Inspection Manual

Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems, the inspectors determined the

finding is of very low safety significance (Green) because the finding did not involve the loss

or degradation of equipment or function specifically designed to mitigate a seismic initiating

event. The finding has a cross-cutting aspect in the area of human performance, associated

with conservative bias, because the licensee did not use decision-making practices that

emphasized prudent choices over those that were simply allowable. Specifically, during the

buried piping initiative inspections that were completed in August 2013, the licensee failed to

identify that the condition of the safety-related piping had never been evaluated and was

being treated as a run to failure component [H.14]. (Section 1R08.2)

-4-

PLANT STATUS

Unit 1 operated at 100 percent power for the entire inspection period.

Unit 2 operated at 100 percent power for the entire inspection period.

REPORT DETAILS

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection (71111.01)

.1 Summer Readiness for Offsite and Alternate AC Power Systems

a. Inspection Scope

On May 1, 2015, the inspectors completed an inspection of the stations off-site and

alternate-ac power systems. The inspectors inspected the material condition of these

systems, including transformers and other switchyard equipment to verify that plant

features and procedures were appropriate for operation and continued availability of off-

site and alternate-ac power systems. The inspectors reviewed outstanding work orders

and open condition reports for these systems. The inspectors walked down the

switchyard to observe the material condition of equipment providing off-site power

sources.

The inspectors verified that the licensees procedures included appropriate measures to

monitor and maintain availability and reliability of the off-site and alternate-ac power

systems.

These activities constituted one sample of summer readiness of off-site and alternate-ac

power systems, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

On March 26, 2015, the inspectors completed an inspection of the stations readiness for

impending adverse weather conditions. The inspectors reviewed plant design features,

the licensees procedures to respond to tornadoes and high winds, and the licensees

implementation of these procedures. The inspectors evaluated operator staffing and

accessibility of controls and indications for those systems required to control the plant.

These activities constituted one sample of readiness for impending adverse weather

conditions, as defined in Inspection Procedure 71111.01.

-5-

b. Findings

Introduction. The inspectors identified a Green non-cited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, & Drawings, for the failure to

establish appropriate procedures for severe weather preparations. Specifically, the

licensee failed to ensure that all outside areas were toured in order to secure material

prior to severe weather, to reduce the probability of light material missile damage on

plant equipment.

Description. The inspectors reviewed Procedures OP-1203.025, Natural Emergencies,

Revision 053, OP-2203.008, Natural Emergencies, Revision 036, and Entergy

Procedure EN-FAP-EP-010, Severe Weather Response, Revision 001. Unit 1

Procedure OP-1203.025, Section 2, Predicted Severe Weather, states, Notify Unit 2

and dispatch Unit 1 personnel to perform walkdowns in the protected area identifying

potential missile hazards using Severe Weather Missile Hazard Reduction Standard,

Attachment 7.15 of EN-FAP-EP-010 as a guide to determine whether materials outside

the plant require resolution. Procedure EN-FAP-EP-010, Attachment 7.15, Severe

Weather Missile Hazard Reduction Standard, stated, in part, that the purpose was to

reduce the chances of light material missile damage on plant facilities.

On March 25, 2015, the National Weather Service issued a severe thunderstorm watch

for Pope County. The inspectors reported to the control room to observe the operators

severe weather preparations. The inspectors observed that the Unit 1 operator did not

tour Unit 2 areas, and that no Unit 2 operator had been dispatched. The inspectors

notified the licensee, and operators subsequently walked down Unit 2 areas.

The inspectors also performed a walkdown of the turbine building roof because the

procedure did not explicitly require a walkdown of the area, and it is physically above

high voltage lines and transformers in the yard. The inspectors discovered debris that

could be potential missile hazards. The licensee subsequently secured the loose items

and documented the concern in Condition Report CR-ANO-C-2015-00859.

The inspectors noted that the procedures failed to provide clear guidance for either the

Unit 1 operator to walk down all areas, or to dispatch a Unit 2 operator. Therefore, the

inspectors concluded that the procedure was inadequate to ensure that all outside areas

were toured in order to secure material prior to severe weather, and in this case did not

meet the purpose statement of EN-FAP-EP-010, Attachment 7.15, referenced above.

The licensee documented the concern in Condition Report CR-ANO-C-2015-00854 and

initiated a standing order to clarify adequate preparations between both units, until a

procedure change could be completed.

Analysis. The failure to have an adequate procedure to ensure that all outside areas

were inspected in order to secure material prior to severe weather to reduce the

probability of light material missile damage on plant equipment, in accordance with

Procedure EN-FAP-EP-010, Severe Weather Response, Revision 1, was a

performance deficiency. The performance deficiency was more than minor because it

was associated with the procedure quality attribute of the Initiating Events Cornerstone

and adversely affected the cornerstone objective to limit the likelihood of events that

upset plant stability and challenge critical safety functions during shutdown as well as

power operations. Specifically, during severe weather, unsecured material could

become a missile that impacts equipment and upsets plant stability. Using NRC

-6-

Inspection Manual Chapter 0609.04, Initial Characterization of Findings, effective

July 1, 2012, and NRC Inspection Manual Chapter 0609, Appendix A, The Significance

Determination Process (SDP) for Findings At-Power, effective July 1, 2012, the

inspectors determined that the finding had very low safety significance (Green) because

it did not represent an actual reactor trip or loss of mitigation equipment. This finding

has a human performance crosscutting aspect associated with work management, in

that the organization failed to implement a process of planning, controlling, and

executing work activities, including coordination with different groups or job activities.

Specifically, only one crew performed the required inspections when severe weather had

been forecast since the procedure in use did not clearly assign responsibilities to both

operating crews [H.5].

Enforcement. Title 10 CFR Part 50, Appendix B, Criterion V, Instruction, Procedures, &

Drawings, states, in part, that activities affecting quality shall be prescribed by

procedures of a type appropriate to the circumstance. Contrary to the above, as of

March 25, 2015, the procedure for severe weather preparations, an activity affecting

quality, was not appropriate to the circumstance. Specifically, Procedure EN-FAP-EP-

010, Severe Weather Response, Revision 1, was unclear in assigning responsibility for

inspecting the entire site for potential missile hazards. The licensee initiated a standing

order to establish adequate preparations for both units until a procedure change could

be completed. This violation is being treated as a non-cited violation, consistent with

Section 2.3.2.a of the Enforcement Policy because it was of very low safety significance

(Green) and it was entered into the licensees corrective action program as Condition

Reports CR-ANO-C-2015-00854 and CR-ANO-C-2015-00859. (NCV 05000313,

368/2015002-01; Inadequate Procedure for Severe Weather Preparation)

1R04 Equipment Alignment (71111.04)

.1 Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walk-downs of the following risk-significant

systems:

• May 5, 2015, Unit 2, turbine driven emergency feedwater train while the motor

driven emergency feedwater train was out of service for maintenance

• May 27, 2015, Unit 1, electric driven fire water pump while the diesel driven fire

water pump was out of service for maintenance

• June 18, 2015, Unit 2, high pressure safety injection train A while train B was out

of service for testing

The inspectors reviewed the licensees procedures and system design information to

determine the correct lineup for the systems. They visually verified that critical portions

of the systems were correctly aligned for the existing plant configuration.

These activities constituted three partial system walk-down samples as defined in

Inspection Procedure 71111.04.

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b. Findings

No findings were identified.

1R05 Fire Protection (71111.05)

.1 Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status

and material condition. The inspectors focused their inspection on four plant areas

important to safety:

• April 15, 2015, Unit 2, Fire Zone 2091-BB, north electrical equipment room

• April 15, 2015, Unit 2, Fire Zone 2099-W, west dc equipment room

• May 1, 2015, Unit 2, Fire Zone Intake, intake structure

• June 10, 2015, Unit 1, Fire Zones 86-G and 87-H, emergency diesel generators

For each area, the inspectors evaluated the fire plan against defined hazards and

defense-in-depth features in the licensees fire protection program. The inspectors

evaluated control of transient combustibles and ignition sources, fire detection and

suppression systems, manual firefighting equipment and capability, passive fire

protection features, and compensatory measures for degraded conditions.

These activities constituted four quarterly inspection samples, as defined in Inspection

Procedure 71111.05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures (71111.06)

a. Inspection Scope

On April 9, 2015, the inspectors completed an inspection of the stations ability to

mitigate flooding due to internal causes. After reviewing the licensees flooding analysis,

the inspectors chose two plant areas containing risk-significant structures, systems, and

components that were susceptible to flooding:

• Unit 1 decay heat watertight vaults

• Unit 2 upper and lower electrical penetration rooms and elevation 335 ft corridor

The inspectors reviewed plant design features and licensee procedures for coping with

internal flooding. The inspectors walked down the selected areas to inspect the design

features, including the material condition of seals, drains, and flood barriers. The

inspectors evaluated whether operator actions credited for flood mitigation could be

successfully accomplished.

-8-

The inspectors reviewed the circumstances surrounding the licensees discovery that a

flood protection seal had been installed in the incorrect location to provide flood

protection for the Unit 2 decay heat removal vaults. The seal was installed as part of

corrective actions to address Yellow finding 2014009-01. This issue was documented in

Condition Report CR-ANO-2-2015-00716, and was dispositioned as an NCV in

inspection report 2015008.

These activities constitute completion of two flood protection measures samples, as

defined in Inspection Procedure 71111.06.

b. Findings

Introduction. The inspectors identified a Green non-cited violation of 10 CFR Part 50,

Appendix B, Criterion III, Design Control, for the failure to select and review equipment

for suitability of application that is essential to the safety-related function of Unit 2 motor

control center (MCC) 2B-52. Specifically, the licensee failed to ensure that the safety-

related electrical equipment inside the MCC was adequately protected from water spray

in the event of a failure of overhead non-seismic category 1 pipes in accordance with the

safety analysis report.

Description. During internal flooding walkdown sample selection, the inspectors

reviewed the Unit 2 safety analysis report, Amendment 23. Section 3.6.4.3.3.4, stated,

in part, that one engineered safety features MCC is located in the passageway near the

spent resin storage tank. Several low-energy non-seismic Category 1 piping systems

pass above this MCC. To protect the MCC from possible spray from these pipes, a

spray shield has been constructed over the MCC.

On April 15, 2015, the inspectors performed a walkdown of the above-described MCC

2B-52 and spray shield. The inspectors noted that the MCC powered red train mitigating

equipment needed to mitigate seismic events, including emergency diesel generator

exhaust fans, containment spray isolation valves, and high pressure safety injection

isolation valves. The inspectors also noted that the spray shield was installed vertically

in front of the cabinet, and determined that the configuration would not protect the

internal equipment from postulated overhead water spray from failed piping. Therefore,

the inspectors concluded that the licensee failed to install the spray shield in accordance

with the safety analysis report, and the mitigation equipment powered by 2B-52 may fail

during a seismic event due to the lack of a spray shield. The licensee initiated Condition

Report CR-ANO-C-2015-01342 to document the inspectors concerns. The licensee

also evaluated the condition to ensure that the overhead pipes, while not fully qualified

for seismic conditions, were sufficiently rugged and therefore unlikely to break during a

seismic event.

The inspectors determined that the condition had existed since plant construction, with

no recent substantial opportunities to identify the issue.

Analysis. The failure to protect Unit 2 MCC 2B-52 from possible spray of overhead non-

seismic category 1 pipes by installing a spray shield in accordance with the safety

analysis report was a performance deficiency. The performance deficiency was more

than minor because it was associated with the design control attribute of the Mitigating

Systems Cornerstone and adversely affected the cornerstone objective to ensure the

reliability of systems that respond to initiating events to prevent undesirable

-9-

consequences. Specifically, the performance deficiency could result in failure of one

train of essential safety features during a seismic event, such as exhaust fans for the

emergency diesel generators, containment spray isolation valves, and high pressure

safety injection isolation valves. Using NRC Inspection Manual Chapter 0609.04, Initial

Characterization of Findings, effective July 1, 2012, and NRC Inspection Manual

Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings

At-Power, effective July 1, 2012, the inspectors determined the finding required a

detailed risk evaluation because the finding involved degradation of equipment

specifically designed to mitigate a seismic event and could degrade one train of a

system that supports a risk significant function. A senior reactor analyst performed the

detailed risk evaluation and estimated the change to the core damage frequency was

3.8E-8/year (Green). The dominant core damage sequences included seismically

induced losses of offsite power. See Attachment 2 for the detailed risk evaluation.

This finding did not have a cross-cutting aspect associated with it because the most

significant contributing cause was not indicative of present performance. Specifically,

the condition had existed since plant construction, with no recent substantial

opportunities to identify the issue.

Enforcement. Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, states, in

part, that for those structures, systems and components (SSCs) to which this appendix

applies, measures shall be established for the selection and review for suitability of

application of materials, parts, equipment, and processes that are essential to the safety-

related functions of the SSCs. Contrary to the above, from construction until

April 15, 2015, for quality-related components associated with Unit 2 MCC 2B-52, to

which 10 CFR Part 50, Appendix B applies, the licensee failed to select and review for

suitability of application of materials, parts, equipment and processes that are essential

to the safety-related function of the component. Specifically, the licensee failed to

ensure that the safety-related electrical equipment inside the MCC was adequately

protected from water spray in the event of a failure of overhead non-seismic category 1

pipes. The licensee evaluated the condition to ensure that the overhead pipes, while not

fully qualified for seismic conditions, were sufficiently rugged and therefore unlikely to

break during a seismic event. This violation is being treated as a non-cited violation,

consistent with Section 2.3.2.a of the Enforcement Policy because it was of very low

safety significance (Green) and it was entered into the licensees corrective action

program as Condition Report CR-ANO-C-2015-01342. (NCV 05000368/2015002-02;

Failure to Protect Motor Control Center from Potential Pipe Spray)

1R08 Inservice Inspection Activities (71111.08)

a. Inspection Scope

This inspection was focused on resolving two Unresolved Items (URIs) opened during

the performance of inspection IP 71111.08, Inservice Inspection Activities, documented

in NRC Inspection Report 05000313; 368/2014003. The inspectors reviewed additional

licensing basis information provided by the licensee, as well as industry standards and

regulatory guidance. The information below documents the resolution of these two URIs.

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b. Findings

.1 Failure to Verify Material Properties Prior to Installation

Introduction. The inspectors reviewed a self-revealing Green finding involving failure to

verify that the proper material was installed in the plant during construction of the Unit 2

reactor coolant system (RCS) sample system.

Description. On February 3, 2014, two through-wall leaks in the supply line to the

reactor coolant sample cooler, 2E30, were identified. The 2E30 heat exchanger is used

to cool samples obtained from the reactor coolant system. These samples are used to

verify the reactor coolant system dose equivalent Xenon-133 specific activity meets

Technical Specification 4.4.8.1, Surveillance for Dose Equivalent Xenon (DEX), which is

required once per 7 days to ensure the acceptability of the system for continued

operation. Follow-up review by the licensee determined that the RCS sample system

had not been built as designed. Design Drawing M-2014-2 specified that ASME SA-479,

Type 304, stainless steel be used in the components. The components were actually

made of carbon steel. Use of the wrong material resulted in through-wall corrosion of

the piping and the reactor coolant system sample system being declared inoperable.

Analysis. The failure to use the correct materials in the Unit 2 reactor coolant sampling

system as specified by design drawings is a performance deficiency. The finding is

more than minor because it is associated with the equipment performance attribute of

the initiating events cornerstone and adversely affects the cornerstone objective to limit

the likelihood of events that upset plant stability and challenge critical safety functions

during shutdown as well as power operations. Specifically, failure to verify the correct

material prior to installation resulted in the failure of the RCS sample system; the inability

to sample the reactor coolant for activity could upset plant stability by necessitating an

unplanned shutdown as required by technical specifications. Using Inspection Manual

Chapter 0609, Attachment 4, Initial Characterization of Findings, dated June 19, 2012,

and Appendix A, The Significance Determination Process (SDP) for Findings At-Power,

dated June 19, 2012, Exhibit 1, Initiating Events Screening Questions, the inspectors

determined that the finding is of very low safety significance (Green) because the finding

did not result in a reactor trip and the loss of mitigation equipment relied upon to

transition the plant from the onset of a trip to a stable shutdown condition. This finding

has not been assigned a cross cutting aspect because the incorrect material was used

during initial construction, and thus not indicative of current plant performance.

Enforcement. This finding did not involve enforcement action because no regulatory

requirements were violated. This issue was entered into licensees corrective action

program as CR-ANO-C-2015-01091. The faulted component was replaced with a

component of the correct material. (FIN 05000368/2015002-03; Failure to Verify

Material Properties Prior to Installation)

.2 Failure to Perform Testing of Diesel Fuel Oil Transfer Piping

Introduction. The inspectors identified a non-cited violation of 10 CFR Part 50,

Appendix B, Criterion XI, Test Control, for the licensees failure to establish and

maintain an adequate testing program for the fuel oil transfer piping for Units 1 and 2.

Specifically, the licensee did not establish inservice inspection requirements to detect

degradation of the fuel oil piping, above ground and buried, between the fuel oil storage

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tanks and the emergency diesel generator day tanks.

Description. During performance of TI 2515/182, Review of the Implementation of the

Industry Initiative to Control Degradation of Underground Piping and Tanks, the

inspectors determined that the fuel oil transfer piping was not included in the licensees

inservice inspection program. During performance of IP 71111.08, Inservice Inspection

Activities, in May 2014, the inspectors further determined that the licensee was not

performing inspections/testing to ensure that fuel oil piping would perform satisfactorily in

service as required by applicable ASME Code requirements. The licensee stated that

the fuel oil transfer systems for both units were designed and built under the construction

permit for Unit 1 to ASME Code B31.1 requirements, and therefore ASME Section XI

inspection requirements were not applicable. When the inspectors requested

documentation to verify that the fuel oil systems for both units were designed and

constructed under the Unit 1 construction permit, the licensee was unable to locate any

documents that confirmed this statement.

The inspectors determined that the fuel oil transfer piping for Units 1 and 2 was safety-

related, seismic Class 1 piping that provided the ability to transfer fuel oil from the fuel oil

storage tanks to the emergency diesel generator day tanks. It was noted by the

inspectors that the requirements of 10 CFR Part 50, Appendix B, were applicable to the

fuel oil transfer piping because the requirements apply to all activities affecting the

safety-related functions of structures, systems, and components. These requirements

include Criterion XI, Test Control, which requires establishment of a test program to

assure that all testing required to demonstrate components will perform satisfactorily is

performed.

The fuel oil transfer piping was designed to non-nuclear ASME Code B31.1 standards.

However, the inspectors determined that inservice testing of the piping in accordance

with ASME Code was still required. Specifically, for facilities with a construction permit

issued prior to January 1, 1971, 10 CFR 50.55a(g)(1) states, in part, that components

(including supports) must meet the requirements of paragraphs (g)(4) and (g)(5) of this

section to the extent practical. Components that are part of the reactor coolant pressure

boundary and their supports must meet the requirements applicable to components that

are classified as ASME Code Class 1. Other safety-related pressure vessels, piping,

pumps and valves, and their supports must meet the requirements applicable to

components that are classified as ASME Code Class 2 or Class 3. Further,

10 CFR 50.55a(g)(4) states, in part, that components which are classified as ASME

Code Class 1, Class 2, and Class 3 must meet the requirements set forth in Section XI

of the ASME Code. Therefore, the inspectors concluded that the piping in question was

required to meet the requirements applicable to ASME Code Class 2 or 3 components,

including the applicable requirements of Section XI. Further, ASME Section XI defines

an appropriate testing program as follows.

ASME Code,Section XI, Table IWD-2500-1, Examination Category D-B, Item No D2.10

requires a system leakage test and a VT-2 visual examination for Class 3 pressure

retaining components. For buried components where a VT-2 visual examination cannot

be performed, IWA-5244(b)(1) requires that, The system pressure test for buried

components that are isolable by means of valves shall consist of a test that determines

the rate of pressure loss. Alternatively, the test may determine the change in flow

between the ends of the buried components.

- 12 -

Analysis. The inspectors determined that the failure to perform testing of fuel oil piping

is a performance deficiency. In accordance with Inspection Manual Chapter 0612

Appendix B, Issue Screening, the issue is more than minor because it is associated

with the protection against external factors attribute of the Mitigating Systems

Cornerstone, and affected the cornerstone objective to ensure availability, reliability, and

capability of systems that respond to initiating events to prevent undesirable

consequence. Specifically, the licensee failed to perform examinations required to

provide reasonable assurance that the piping can perform its intended function during

design basis seismic events, and therefore maintain the ability to supply fuel to the

emergency diesel generators. The inspectors evaluated the finding using NRC

Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems. The

inspectors determined the finding is of very low safety significance (Green) because the

finding did not involve the loss or degradation of equipment or function specifically

designed to mitigate a seismic initiating event. The finding has a cross-cutting aspect in

the area of human performance, associated with conservative bias because the licensee

did not use decision making-practices that emphasized prudent choices over those that

were simply allowable. Specifically, during the buried piping initiative inspections that

were completed in August 2013, the licensee failed to identify that the condition of the

safety-related piping had never been evaluated and was being treated as a run to failure

component. [H.14]

Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XI, Test Control, requires, in

part, that a test program shall be established to assure that all testing required to

demonstrate that SSCs will perform satisfactorily in service is identified and performed in

accordance with written procedures which incorporate the requirements and acceptance

limits contained in applicable design documents.

For facilities with a construction permit issued prior to January 1, 1971,

10 CFR 50.55a(g)(1) states, in part, that components (including supports) must meet the

requirements of paragraphs (g)(4) and (g)(5) of this section to the extent practical.

Components that are part of the reactor coolant pressure boundary and their supports

must meet the requirements applicable to components that are classified as ASME Code

Class 1. Other safety-related pressure vessels, piping, pumps and valves, and their

supports must meet the requirements applicable to components that are classified as

ASME Code Class 2 or Class 3.

Title 10 CFR 50.55a(g)(4) states, in part, that components which are classified as ASME

Code Class 1, Class 2, and Class 3 must meet the requirements set forth in Section XI

of the ASME Code.

ASME Code,Section XI, Table IWD-2500-1, Examination Category D-B, Item No D2.10

requires a system leakage test and a VT-2 visual examination for pressure retaining

components. For buried components where a VT-2 visual examination cannot be

performed, IWA-5244(b)(1) requires that the system pressure test for buried components

that are isolable by means of valves shall consist of a test that determines the rate of

pressure loss. Alternatively, the test may determine the change in flow between the

ends of the buried components.

Contrary to the above, from initial commercial operations to the April 29, 2015, the

licensee failed to establish a test program to assure that all testing required to

- 13 -

demonstrate that the fuel oil transfer piping will perform satisfactorily in service is

identified and performed in accordance with written procedures which incorporate the

requirements and acceptance limits contained in applicable design documents.

Specifically, the licensee did not establish inservice inspection examinations and testing

required by 10 CFR 50.55a(g)(1) and (g)(4) and as specified by ASME Code Section XI,

Table IWD-2500-1 and IWA- 5244(b)(1) to detect degradation of the fuel oil piping,

above ground and buried, between the fuel oil storage tanks and the emergency diesel

generator day tanks. Since the violation is of very low safety significance and is

documented in the licensees corrective action program as Condition Report CR-ANO-2-

2015-01092, it is being treated as a non-cited violation, consistent with Section 2.3.2.a of

the Enforcement Policy. (NCV 05000313, 368/2015002-04; Failure to Perform Testing

of Diesel Fuel Oil Transfer Piping)

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

(71111.11)

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On May 20, 2015, the inspectors observed Unit 2 simulator training for an operating

crew. On June 17, 2015, the inspectors observed a Unit 1 simulator examination for an

operating crew. The inspectors assessed the performance of the operators and the

evaluators critique of their performance.

These activities constitute completion of two quarterly licensed operator requalification

program samples, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

The inspectors observed the performance of on-shift licensed operators in the plants

Unit 1 and Unit 2 main control rooms. The inspectors observed the operators

performance of the following activities:

• April 15, 2015, Unit 1, control rod exercises

• May 29, 2015, Unit 2, emergency diesel generator A surveillance

In addition, the inspectors assessed the operators adherence to plant procedures,

including conduct of operations procedure and other operations department policies.

These activities constitute completion of two quarterly licensed operator performance

samples, as defined in Inspection Procedure 71111.11.

- 14 -

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness (71111.12)

a. Inspection Scope

The inspectors reviewed two instances of degraded performance or condition of SSCs

that were important to safety:

• March 13, 2015, Unit 1, instrument air dryer supply line rupture

• March 13, 2015, Unit 1, reactor building tendon grease leaks

The inspectors reviewed the extent of condition of possible common cause SSC failures

and evaluated the adequacy of the licensees corrective actions. The inspectors

reviewed the licensees work practices to evaluate whether these may have played a

role in the degradation of the SSCs. The inspectors assessed the licensees

characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance

Rule), and verified that the licensee was appropriately tracking degraded performance

and conditions in accordance with the Maintenance Rule.

These activities constituted completion of two maintenance effectiveness samples, as

defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. Inspection Scope

The inspectors reviewed two risk assessments performed by the licensee prior to

changes in plant configuration and the risk management actions taken by the licensee in

response to elevated risk:

• May 6, 2015, Unit 1, loop 2 service water to intermediate cooling water cooler

isolation valve, CV-3811, out of service

• June 10, 2015, Unit 1, emergency diesel generator B out of service

The inspectors verified that these risk assessments were timely and in accordance with

the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The

inspectors reviewed the accuracy and completeness of the licensees risk assessments

and verified that the licensee implemented appropriate risk management actions based

on the result of the assessments.

The inspectors also observed portions of an emergent work activity that had the potential

to cause an initiating event. On May 5, 2015, the inspectors observed Unit 2 motor

control center 2B-53 maintenance due to high resistance connections that had the

potential to cause a fault and/or fire.

- 15 -

The inspectors verified that the licensee appropriately developed and followed a work

plan for these activities. The inspectors verified that the licensee took precautions to

minimize the impact of the work activities on unaffected SSCs.

These activities constitute completion of two maintenance risk assessments and

emergent work control inspection samples, as defined in Inspection Procedure 71111.13.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments (71111.15)

a. Inspection Scope

The inspectors reviewed seven operability determinations that the licensee performed

for degraded or nonconforming SSCs:

• April 16, 2015, Unit 2, operability determination for the turbine driven emergency

feedwater pump with a steam trap drain inadvertently left partially open

• April 7, 2015, Unit 1, operability determination for CV-1000 and CV-1009,

electromatic relief valve block valve and pressurizer spray block valve

environmental qualification configuration

• April 23, 2015, Unit 1, operability determination for the penetration room

ventilation system with damper CV-2100 failed to fully close

• May 4, 2015, Unit 1, operability determination for loop 2 service water when

CV-3811 failed to close

• May 7, 2015, Unit 2, operability determination for abnormal noise inside inverter

2Y22

• May 19, 2015, Unit 1, operability determination for turbine-driven emergency

feedwater pump increased speed setting

• May 27, 2015, Unit 2, operability determination for startup transformer 3 voltage

regulator following damage to cabling from debris during high winds

The inspectors reviewed the timeliness and technical adequacy of the licensees

evaluations. Where the licensee determined the degraded SSC to be operable, the

inspectors verified that the licensees compensatory measures were appropriate to

provide reasonable assurance of operability. The inspectors verified that the licensee

had considered the effect of other degraded conditions on the operability of the

degraded SSC.

These activities constitute completion of seven operability and functionality review

samples, as defined in Inspection Procedure 71111.15.

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b. Findings

No findings were identified.

1R18 Plant Modifications (71111.18)

a. Inspection Scope

On April 15, 2015, the inspectors reviewed a temporary modification to disable a

degraded Unit 2 upper gripper coil for control element assembly 18.

The inspectors verified that the licensee had installed this temporary modification in

accordance with technically adequate design documents. The inspectors verified that

this modification did not adversely impact the operability or availability of affected SSCs.

The inspectors reviewed design documentation and plant procedures affected by the

modification to verify the licensee maintained configuration control.

These activities constitute completion of one sample of temporary modifications, as

defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed four post-maintenance testing activities that affected

risk-significant SSCs:

• April 24, 2015, Unit 2, motor control center 2B-35, following repair activities due

to a fault

• May 3, 2015, Unit 1, motor control center B-33, following preventative

maintenance

• May 5, 2015, Unit 2, motor driven emergency feedwater discharge to steam

generator B valve 2CV-1036-2, following preventative maintenance

• May 6, 2015, Unit 1, loop 2 service water to intermediate cooling water cooler

isolation valve CV-3811, following emergent maintenance

The inspectors reviewed licensing- and design-basis documents for the SSCs and the

maintenance and post-maintenance test procedures. The inspectors observed the

performance of the post-maintenance tests to verify that the licensee performed the tests

in accordance with approved procedures, satisfied the established acceptance criteria,

and restored the operability of the affected SSCs.

These activities constitute completion of four post-maintenance testing inspection

samples, as defined in Inspection Procedure 71111.19.

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b. Findings

No findings were identified.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors observed seven risk-significant surveillance tests and reviewed test

results to verify that these tests adequately demonstrated that the SSCs were capable of

performing their safety functions:

In-service tests:

• June 19, 2015, Unit 2, high pressure safety injection train B pump in-service test

Reactor coolant system leak detection tests:

• May 29, 2015, Unit 1, reactor coolant system leak detection surveillance

• May 29, 2015, Unit 2, reactor coolant system leak detection surveillance

Other surveillance tests:

• April 23, 2015, Unit 1, penetration room ventilation system surveillance test

• May 28, 2015, Unit 1, reactor coolant system chemistry sampling

• May 28, 2015, Unit 2, reactor coolant system chemistry sampling

• May 29, 2015, Unit 2, emergency diesel generator A monthly surveillance

The inspectors verified that these tests met technical specification requirements, that the

licensee performed the tests in accordance with their procedures, and that the results of

the test satisfied appropriate acceptance criteria. The inspectors verified that the

licensee restored the operability of the affected SSCs following testing.

These activities constitute completion of seven surveillance testing inspection samples,

as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation (71114.06)

Inspection Scope

On June 17, 2015, the inspectors observed simulator-based licensed operator

requalification training that included implementation of the licensees emergency plan.

The inspectors verified that the licensees emergency classifications, off-site

notifications, and protective action recommendations were appropriate and timely. The

- 18 -

inspectors verified that any emergency preparedness weaknesses were appropriately

identified by the evaluators and entered into the corrective action program for resolution.

These activities constitute completion of one training observation sample, as defined in

Inspection Procedure 71114.06.

a. Findings

No findings were identified.

2. RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS2 Occupational ALARA Planning and Controls (71124.02)

a. Inspection Scope

The inspectors assessed licensee performance with respect to maintaining occupational

individual and collective radiation exposures as low as is reasonably achievable

(ALARA). During the inspection, the inspectors interviewed licensee personnel and

reviewed licensee performance in the following areas:

• Site-specific ALARA procedures and collective exposure history, including the

current 3-year rolling average, site-specific trends in collective exposures, and

source-term measurements

• ALARA work activity evaluations/postjob reviews, exposure estimates, and

exposure mitigation requirements

• The methodology for estimating work activity exposures, the intended dose

outcome, the accuracy of dose rate and man-hour estimates, and intended

versus actual work activity doses and the reasons for any inconsistencies

• Records detailing the historical trends and current status of tracked plant source

terms and contingency plans for expected changes in the source term due to

changes in plant fuel performance issues or changes in plant primary chemistry

• Radiation worker and radiation protection technician performance during work

activities in radiation areas, airborne radioactivity areas, or high radiation areas

• Audits, self-assessments, and corrective action documents related to ALARA

planning and controls since the last inspection

These activities constitute completion of one sample of occupational ALARA planning

and controls as defined in Inspection Procedure 71124.02.

b. Findings

No findings were identified.

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2RS4 Occupational Dose Assessment (71124.04)

a. Inspection Scope

The inspectors evaluated the accuracy and operability of the licensees personnel

monitoring equipment, verified the accuracy and effectiveness of the licensees methods

for determining total effective dose equivalent, and verified that the licensee was

appropriately monitoring occupational dose. The inspectors interviewed licensee

personnel, walked down various portions of the plant, and reviewed licensee

performance in the following areas:

• External dosimetry accreditation, storage, issue, use, and processing of active

and passive dosimeters

• The technical competency and adequacy of the licensees internal dosimetry

program

• Adequacy of the dosimetry program for special dosimetry situations such as

declared pregnant workers, multiple dosimetry placement, and neutron dose

assessment

• Audits, self-assessments, and corrective action documents related to dose

assessment since the last inspection

These activities constitute completion of one sample of occupational dose assessment

as defined in Inspection Procedure 71124.04.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation (71124.08)

.1 Shipment Preparation (02.05)

a. Inspection Scope

The inspectors observed shipment packaging, surveying, labeling, marking, placarding,

vehicle checks, emergency instructions, disposal manifest, shipping papers provided to

the driver, and licensee verification of shipment readiness. The inspectors assessed

whether the requirements of applicable transport cask certificate of compliance had been

met. The inspectors evaluated whether the receiving licensee was authorized to receive

the shipment packages. The inspectors evaluated whether the licensees procedures for

cask loading and closure procedures were consistent with the vendors current approved

procedures.

These inspection activities supplement those documented in Inspection

Report 05000313/2015002 and constitute sample as defined in IP 71124.08-05.

- 20 -

b. Findings

No findings were identified.

4. OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency

Preparedness, Public Radiation Safety, Occupational Radiation Safety, and

Security

4OA1 Performance Indicator Verification (71151)

.1 Safety System Functional Failures (MS05)

a. Inspection Scope

For the period of April 1, 2014, through March 31, 2015, the inspectors reviewed

licensee event reports (LERs), maintenance rule evaluations, and other records that

could indicate whether safety system functional failures had occurred. The inspectors

used definitions and guidance contained in Nuclear Energy Institute Document 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 7, and

NUREG-1022, Event Reporting Guidelines: 10 CFR 50.72 and 50.73, Revision 3, to

determine the accuracy of the data reported.

These activities constituted verification of the safety system functional failures

performance indicator for Unit 1 and Unit 2, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Reactor Coolant System Specific Activity (BI01)

a. Inspection Scope

The inspectors reviewed the licensees Unit 1 and Unit 2 reactor coolant system

chemistry sample analyses for the period of April 1, 2014, through March 31, 2015, to

verify the accuracy and completeness of the reported data. The inspectors observed a

chemistry technician obtain and analyze a Unit 1 and Unit 2 reactor coolant system

sample on May 28, 2015. The inspectors used definitions and guidance contained in

Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance

Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the reactor coolant system specific activity

performance indicator for Unit 1 and Unit 2, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

- 21 -

.3 Reactor Coolant System Total Leakage (BI02)

a. Inspection Scope

The inspectors reviewed the licensees records of Unit 1 and Unit 2 reactor coolant

system total leakage for the period of April 1, 2014, through March 31, 2015, to verify the

accuracy and completeness of the reported data. The inspectors observed the

performance of Unit 1 RCS leak detection surveillance procedure on May 29, 2015 and

Unit 2 RCS leak detection surveillance procedure on May 28, 2015. The inspectors

used definitions and guidance contained in Nuclear Energy Institute Document 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the

accuracy of the reported data.

These activities constituted verification of the reactor coolant system leakage

performance indicator for Unit 1 and Unit 2, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution (71152)

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items

entered into the licensees corrective action program and periodically attended the

licensees condition report screening meetings. The inspectors verified that licensee

personnel were identifying problems at an appropriate threshold and entering these

problems into the corrective action program for resolution. The inspectors verified that

the licensee developed and implemented corrective actions commensurate with the

significance of the problems identified. The inspectors also reviewed the licensees

problem identification and resolution activities during the performance of the other

inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Semiannual Trend Review

a. Inspection Scope

The inspectors reviewed the licensees corrective action program, performance

indicators, system health reports, and other documentation to identify trends that might

indicate the existence of a more significant safety issue. The inspectors verified that the

licensee was taking corrective actions to address identified adverse trends.

These activities constitute completion of one semiannual trend review sample, as

defined in Inspection Procedure 71152.

- 22 -

b. Observations and Assessments

Roof Leaks

On April 1, 2015, Unit 2 MCC 2B-35 electrically shorted. The licensee evaluated the

fault in Condition Report CR-ANO-2-2015-00902 and determined that a contributor to

the fault was past water intrusion due to an overhead roof leak.

On May 4, 2015, the licensee identified that there was an adverse trend regarding roof

leaks at the facility, including two auxiliary building leaks, nine turbine building leaks, a

leak at the alternate ac diesel generator building, and radioactive waste building leaks.

Some of the roof leaks have been long term, and now require large sections of the roof

to be replaced to correct the leakage. The licensee documented the observation in

Condition Report CR-ANO-C-2015-01390, and plans to fix the leaks.

The inspectors observed that the licensee has taken action to protect plant equipment

from wetting, such as tarps. However, as evidenced by the MCC 2B-35 fault, the

inspectors concluded that plant equipment was more susceptible to wetting and damage

due to the number and duration of the roof leaks.

Alternate Ac Diesel Generator Ventilation

The inspectors observed a negative trend related to ventilation equipment for the

alternate ac diesel generator, a safety significant electrical supply for Units 1 and 2.

The inspectors observed that 2VSF-32, the electrical room cooler, had tripped multiple

times within the past year. The inspectors also observed that, as documented in

Condition Report CR-ANO-C-2015-01729, it was very difficult for operators to diagnose

that the coolers breaker had tripped, due to the breaker design. The electrical room

exhaust fan, 2VEF-19, had been available each time that 2VSF-32 was out of service,

so the diesel generator remained available. However, due to the increased unreliability

and the difficulty of diagnosis, the inspectors concluded that there was an increased

probability of concurrent out of service time for fans 2VSF-32 and 2VEF-19, which would

cause diesel generator unavailability. The licensee documented the inspectors concern

in Condition Report CR-ANO-C-2015-01935.

The inspectors observed that 2VEF-18, the diesel generator room exhaust fan, had also

tripped multiple times within the past year. A second room exhaust fan, 2VEF-17, had

been available each time that 2VEF-18 was out of service. If outside air temperature

exceeds 92 degrees Fahrenheit with 2VEF-18 out of service and 2VEF-17 available,

then the diesel generator would be unavailable. However, the inspectors observed that

when 2VEF-18 was out of service, operators were not tracking outside air temperature to

ensure that the diesel generator remained available. The inspectors reviewed actual

temperature data for those periods and determined that the diesel generator remained

available. The licensee documented the inspectors concern in Condition Report

CR-ANO-C-2015-01770.

The licensee has addressed the equipment failures through the corrective action

program, and the maintenance rule program trends the ventilation equipment failures.

However, the inspectors concluded that the licensee had failed to identify and correct the

human factors that contributed to reliability of the alternate ac diesel generator; namely,

- 23 -

operator walkdowns to ensure standby equipment is available, and tracking degraded

conditions to ensure the standby equipment remained available.

c. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion (71153)

.1 (Closed) Licensee Event Report 05000368/2014-004-00, Technical Specification 3.0.4

Violation due to a Mode Change with an Inoperable Emergency Feedwater Pump

a. Inspection Scope

Revision 01 of this licensee event report was reviewed and closed in NRC Inspection

Report 05000368/2015001, Section 4OA3.3. No additional deficiencies were identified

during review of Revision 00 of this licensee event report. This licensee event report is

closed.

b. Findings

No findings were identified.

.2 Event Follow-up for Unirradiated Nuclear Fuel Damage

a. Inspection Scope

On April 13, 2015, as Unit 2 new fuel assemblies were being transferred from the new

fuel storage rack to the spent fuel pool in preparations for refueling outage 2R24, a fuel

assembly was damaged. One operator initiated raising the new fuel elevator before

another operator had moved the assembly clear of the elevator travel path. The fuel

assembly was impacted by the top of the new fuel elevator resulting in the fuel assembly

being determined unacceptable for use in the core. The inspectors verified the status of

safety equipment and barriers, assessed radiological impacts, and observed command

and control functions. The inspectors also performed a walkdown to verify that the

damaged assembly was stabilized and that spent fuel assemblies were not affected.

b. Findings

No findings were identified.

These activities constitute completion of one event follow-up sample, as defined in

Inspection Procedure 71153.

4OA5 Other Activities

Quarterly Performance Assessment

In the NRCs annual assessment letter (ML15063A499), dated March 4, 2015, the NRC

documented that the performance of Arkansas Nuclear One, Units 1 and 2, was within

- 24 -

the Multiple/Repetitive Degraded Cornerstone Column (Column 4) of the NRCs Reactor

Oversight Process Action Matrix.

In accordance with NRC Inspection Manual Chapter 0305, Operating Reactor

Assessment Program, Issued April 9, 2015, a quarterly review of performance is

required for a plant whose performance is in Column 4 of the Action Matrix.

On July 1, 2015, NRC management reviewed inspection and performance indicator

results for Units 1 and 2. The NRC determined that continued plant operation was

acceptable in the Multiple/Repetitive Degraded Cornerstone of the Reactor Oversight

Process Action Matrix. In addition, no additional regulatory actions beyond those

described in the annual assessment letter were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On April 29, 2015, the inspectors presented the inservice inspection activities results to

Mrs. S. Pyle, Regulatory Assurance Manager and other members of the licensee staff. The

licensee acknowledged the issues presented. The inspectors confirmed none of the information

reviewed was proprietary.

On May 12, 2015, the inspectors held a public meeting at the Lakepoint Conference Center in

London, Arkansas, to present the results of the 2014 end-of-cycle performance review of

Arkansas Nuclear One, Units 1 and 2. The inspectors presented inspection results and

enforcement actions from January 1, 2014, through December 31, 2014.

On May 21, 2015, the NRC held a public Commission Meeting to discuss the results of the

Agency Action Review Meeting in Rockville, Maryland. The NRC staff and licensee discussed,

in part, performance at Arkansas Nuclear One and performance improvement plans with the

Commission.

On June 25, 2015 the inspectors presented the radiation safety inspection results to Mr. D.

James, Director, Regulatory Affairs, and other members of the licensee staff. The licensee

acknowledged the issues presented. The licensee confirmed that any proprietary information

reviewed by the inspectors had been returned or destroyed.

On July 9, 2015, the inspectors presented the inspection results to Mr. J. Browning, and other

members of the licensee staff. The licensee acknowledged the issues presented. The licensee

confirmed that any proprietary information reviewed by the inspectors had been returned or

destroyed.

- 25 -

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. Barborek, Engineer

R. Barnes, Director, Regulatory Affair & Performance Indicators

L. Blocker, Nuclear Oversight Manager

J. Browning, Site Vice President

P. Butler, Design and Program Engineering Manager

B. Daiber, Recovery Manager

B. Davis, Engineering Director

G. Doran, Specialist, Radiation Protection

T. Evans, General Manager of Plant Operations

K. Gaston, Engineer

M. Gibson, Supervisor, ALARA

D. James, Director, Regulatory Affairs & Recovery

D. Marvel, Radiation Protection Manager

N. Mosher, Licensing Specialist

D. Pehrson, Unit 1 Assistant Operations Manager

S. Pyle, Regulatory Assurance Manager

B. Short, Senior Licensing Specialist

M. Smith, Coordinator, ALARA

J. Toben, Security Manager

D. Varvil, Engineer

NRC

D. Alley, Chief, Component Integrity Branch

T. Lupold, Chief, Mechanical and Civil Engineering Branch

S. Cumbridge, Component Integrity Branch

J. Tsao, Component Integrity Branch

K. Hoffman, Component Integrity Branch

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000313/2015002-01 NCV Inadequate Procedure for Severe Weather Preparation)05000368/2015002-01 (Section 1R01.2)05000368/2015002-02 NCV Failure to Protect Motor Control Center from Potential Pipe

Spray (Section 1R06)05000368/2015002-03 FIN Failure to Verify Material Properties Prior to Installation

(Section 1R08.1)

A-1 Attachment 1

Opened and Closed

05000313/2015002-04 NCV Failure to Perform Testing of Diesel Fuel Oil Transfer Piping

05000368/2015002-04 (Section 1R08.2)

Closed

05000368/2014003-05 URI Proper ASME Code Classification of RCS Sample System

(Section 1R08)05000368/2014003-06 URI Inservice Testing of the Diesel Fuel Oil Transfer Piping

(Section 1R08)05000368/2014004-00 LER Technical Specification 3.0.4 Violation due to a Mode

Change with an Inoperable Emergency Feedwater Pump

(Section 4OA3)

A1-2

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

Procedures

Number Title Revision

OP-1203.025 Natural Emergencies 053

EN-FAP-EP-010 Severe Weather Response 001

OP-1015.044 Summer Reliability Operations 009

ENS-DC-201 ENS Transmission Grid Monitoring 006

ENS-DC-199 Off Site Power Supply Design Requirements Nuclear Plant 009

Interface Requirements

ENS-PL-159 Summer Reliability Plan 000

ENS-PL-158 Switchyard and Transmission Interface Requirements 036

Section 1R04: Equipment Alignment

Procedures

Number Title Revision

OP-2106.006 Emergency Feedwater System Operations 089

OP-1104.032 Fire Protection Systems 083

OP-2104.039 HPSI System Operation 077

Drawings

Number Title Revision

M-2232 Piping & Instrument Diagram Safety Injection System 120

M-2236 Piping & Instrument Diagram Containment Spray System 095

Section 1R05: Fire Protection

Procedures

Number Title Revision

FHA Fire Hazards Analysis 016

2A-372-2099-W West DC Equipment Room 002

A1-3

Procedures

Number Title Revision

FHA Fire Hazards Analysis 016

2A-372-2091-BB North Electrical Equipment (2Y22/2Y24) Room 003

2b-add-unit2 Unit 2 Intake Structure 002

intake

Drawings

Number Title Revision

FZ-2056 Fire Zone Detail - West Battery Room and West DC 002

Equipment Room

FZ-2027 Fire Zone Detail - Electrical Equipment Room 003

FZ-2010 Fire Zone Detail - Intake Structure 002

FZ-2035 Fire Zone Detail - Intake Structure 002

Section 1R06: Flood Protection Measures

Miscellaneous

Number Title Revision

ULD-0-TOP-17 Design Configuration Documentation Project ANO Flooding 000

Topical

Section 1R08: Inservice Inspection Activities

Miscellaneous

Number Description or Title Revision

ANSI N195-1976 Fuel Oil Systems for Standby Diesel-Generators

EC-49008 2TCD-19-1 sheet 1 006

6600-M-2084 Drawing of RCS Sample System Sheet 73 023

2305-017 Local Leak Rate Testing 031

M2014-2 Reactor Sample System Piping Diagram 002

6600-2 Field Change Notice to reroute piping of Reactor Sample

System

6600-M-2084 Reactor Sample System Piping Diagram Sheet 73 003

A1-4

Miscellaneous

Number Description or Title Revision

ANO-M-2514 Technical Specification for the Design of Piping for ANO 002

Units 1 and 2

Section 1R11: Licensed Operator Requalification Program and Licensed Operator

Performance

Procedures

Number Title Revision

1105.009 CRD System Operating Procedure 049

1015.001 Conduct of Operations 109

Miscellaneous

Number Title Revision

SES-1-039 Unit 1 Dynamic Exam Scenario 002

Section 1R12: Maintenance Effectiveness

Procedures

Number Title Revision

OP-2106.006 Emergency Feedwater System Operations 084

EN-MA-125 Troubleshooting Control of Maintenance Activities 017

Condition Reports (CRs)

CR-ANO-1-2015-00370 CR-ANO-1-2015-01829 CR-ANO-1-2015-01594

CR-ANO-2-2015-00497 CR-ANO-C-2015-00756 CR-ANO-1-2015-00054

CR-ANO-1-2013-01988

Miscellaneous

Number Title Revision

Maintenance Rule A(1) Plan for 1IA

A1-5

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures

Number Title Revision

EN-WM-104 On Line Risk Assessment 011

OP-2107.002 ESF Electrical System Operation 031

OP-2412.074 Unit 2 AC Motor Control Centers 018

Work Orders (WOs)

412506-01

Condition Reports (CRs)

CR-ANO-1-2015-02032 CR-ANO-1-2015-02016 CR-ANO-2-2015-01057

CR-ANO-1-2015-02017

Section 1R15: Operability Determinations and Functionality Assessments

Procedures

Number Title Revision

EN-LI-102 Corrective Action Program 024

EN-OP-104 Operability Determination Process 008

EN-OP-103 Reactivity Management Program 005

EN-HU-101 Human Performance Program 015

EN-LI-118 Cause Evaluation Process 021

OP-2106.006 Emergency Feedwater System Operations 089

EN-FAP-OP-010 Component Misposition Performance Indicator 001

STM 1-11 AB, Spent Fuel, Penetration Room Ventilation Systems 009

OP-2107.003 Inverter and 120 VAC Electrical System Operation 032

Miscellaneous

Number Title Date

1104.002 Sup 4 Quarterly HPI Pump (P-36B) Test October 27, 2014

Condition Reports (CRs)

CR-ANO-2-2014-03572 CR-ANO-2-2014-03115 CR-ANO-1-2015-01914

A1-6

CR-ANO-2-2014-02546 CR-ANO-2-2015-01026 CR-ANO-1-2015-01917

CR-ANO-2-2015-00976 CR-ANO-2-2015-00353 CR-ANO-2-2015-00343

CR-ANO-2-2015-00344 CR-ANO-1-2015-02205 CR-ANO-2-2015-01342

Section 1R18: Plant Modifications

Procedures

Number Title Revision

STM 2-02 Control Element Drive Mechanism Control System 018

Miscellaneous

Number Title Revision

TMOD 54932 Removal of CEA-18 Upper Gripper Coil 001

Work Orders (WOs)

00402629-01

Section 1R19: Post-Maintenance Testing

Procedures

Number Title Revision

OP-2106.006 Emergency Feedwater System Operations, Supplement 3A 089

OP-1104.029 Service Water and Auxiliary Cooling System 110

OP-1412.054 Unit 1 AC Motor Control Centers 030

Drawings

Number Title Revision

E-2025 480 Volt Motor Control Center B33 & 2B72 Post Accident 003

Sampling Facility

Work Orders (WOs)

412512-01 412507-01 412507-04 412507-05

A1-7

Section 1R22: Surveillance Testing

Procedures

Number Title Revision

OP-1104.043 Penetration Room Ventilation System 028

OP-1607.001 Reactor Coolant System Sampling 021

OP-2607.001 Unit 2 Reactor Coolant System Sampling 021

OP-1103.013 RCS Leak Detection 040

OP-2305.002 Reactor Coolant System Leak Detection 025

OP-2104.036 Emergency Diesel Generator Operations 087

OP-2104.039 HPSI System Operation 077

Work Orders (WOs)

52561841

Condition Reports (CRs)

CR-ANO-2-2015-01638

Section 1EP6: Drill Evaluation

Miscellaneous

Number Title Revision

SES-1-039 Unit 1 Dynamic Exam Scenario 002

Section 2RS2: Occupational ALARA Planning and Controls

Procedures

Number Title Revision

1000.031 Radiation Protection Manual 020-00-0

EN-RP-105 Radiological Work Permits 14

EN-RP-110 ALARA Program 12

EN-RP-110-01 ALARA Initiative Deferals 01

EN-RP-110-02 Elemental Cobalt Sampling 00

EN-RP-110-03 Collective Radiation Exposure (CRE) Reduction Guidelines 04

EN-RP-110-04 Radiation Protection Risk Assessment Process 05

EN-RP-110-05 Personnel Monitoring 02

A1-8

EN-RP-110-06 Outage Dose Estimating and Tracking 01

EN-RP-204 Special Monitoring Requirements 06 & 08

Audits, Self-Assessments, And Surveillances

Number Title Date

1R25 ALARA Report Undated

2R23 ALARA Report Undated

LO- ALO-LO-2013-00110 Radiation Protection Triennial Assessment August 5, 2014

Condition Reports (CRs)

HQN-2014-00645 C-2014-00916 C-2015-0007 C-2015-00552

HQN-2015-00321 C-20015-01891

Miscellenous Documents

Title Date

Arkansas Nuclear One Annual Radiation Protection Report 2015-0026

Arkansas Nuclear One 5-Year Exposure Reduction Plan 2015-2019

RWP 2014-2450; ISI and Alloy 600 Inspections (Excluding RVCH) Revision 00

RWP 2015-1407 Decontamination Activities 1R15 Revision 00

RWP 2015-1420; Scaffold Instalation and Removal Revision 00

RWP 2015-1450; ISI and Alloy 600 Inspections (Excluding RVCH) Revision 02

Selected Radiation Surveys; Units 1 and Units 2 Various Dates 2014

& 2015

Section 2RS4: Occupational Dose Assessment

Procedures

Number Title Revision

EN-RP-131 Air Sampling 13

EN-RP-201 Dosimetry Administration 4

EN-RP-202 Personnel Monitoring 9

EN-RP-203 Dose Assessment 6

EN-RP-204 Special Monitoring Requirements 6

EN-RP-205 Prenatal Monitoring 3

EN-RP-206 Dosimeter of Legal Record QA 5

EN-RP-208 Whole Body Counting/In-Vitro Bioassay 6

Audits, Self-Assessments, And Surveillances

Number Title Date

LO- ALO-LO-2013-00110 Radiation Protection Triennial Assessment August 5, 2014

A1-9

Condition Reports (CRs)

C-2014-00897 C-2014-02730 C-2015-00343 C-2015-00690 C-2015-01333

Miscellaneous Documents

Title Date

ANO Part 61 Scaling Analyses April 17, 2015

Whole Body Counting Report 1st Qtr 2015

Whole Body Counting Report 4th Qtr 2014

Whole Body Counting Report 3rd Qtr 2014

Whole Body Counting Report 2nd Qtr 2014

Section 2RS8: Radioactive Solid Waste Processing, and Radioactive Material Handling,

Storage, and Transportation

Procedures

Number Title Revision

EN-RW-101 Radioactive Waste Management 3

EN-RW-102 Radioactive Shipping Procedure 12

EN-RW-103 Radioactive Waste Tracking Procedure 4

EN-RW-104 Scaling Factors 11

EN-RW-105 Process Control Program 4

EN-RW-106 Integrated Transportation Security Plan 4

Radioactive Materials/Waste Shipments

Number Title Date

RSR-15-075 Low Activity Spent Resin Type B LSA-II June 24, 2015

RSR-15-077 Low Activity DAW Metal Oxides Type A LSA-I June 23, 2015

Section 4OA1: Performance Indicator Verification

Miscellaneous

Number Title Date

ANO-1 Tech Spec and TRM Surveillance Report May 25, 2015

ANO-1 Tech Spec and TRM Surveillance Report May 27, 2015

ANO-2 Tech Spec and TRM Surveillance Report May 25, 2015

ANO-2 Tech Spec and TRM Surveillance Report May 27, 2015

A1-10

Condition Reports (CRs)

CR-ANO-C-2013-01304

Section 4OA2: Problem Identification and Resolution

Procedures

Number Title Revision

OP-2104.037 Alternate AC Diesel Generator Operations 29

Condition Reports (CRs)

CR-ANO-C-2015-01770 CR-ANO-2-2015-00902 CR-ANO-2-2015-01387

CR-ANO-C-2014-01809 CR-ANO-C-2015-02123 CR-ANO-2-2015-01754

CR-ANO-C-2015-01729 CR-ANO-C-2015-01935 CR-ANO-C-2015-01390

Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion

Condition Reports (CRs)

CR-ANO-2-2015-00805

A1-11

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget,

control number 3150-0011.

The following items are requested for the Occupational Radiation Safety: ALARA &

Access Control and Occupational Dose Assessment Inspection at ANO from

June 22 - 25, 2015, Inspection Report Number 05000-313 & 368/2015-002.

Please provide the requested information to Louis C. Carson II and Marty Phalen in the

Region IV Arlington Office by June 15, 2015. In an effort to keep the requested information

organized please submit the information to us using the same numbering/lettering system

below. Thank you for your support.

Inspection areas are listed in the attachments below.

Please submit this information using the same lettering system as below. For example, all

contacts and phone numbers for Inspection Procedure 71124.02 should be in a file/folder titled

1- A, applicable organization charts in file/folder 1- B, etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at

least 30 days later than the onsite inspection dates, so the inspectors will have access to the

information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please call me at 817-200-1221 or Email

Louis.Carson@nrc.gov or Marty.Phalen@nrc.gov ; 817-200-1158.

A-1 Attachment

1. Items needed to support the ALARA Planning & Controls (71124.02) Inspection to be

conducted by Louis C. Carson II are as follows:

Date of Last Inspection: March 20, 2014

A. List of contacts and telephone numbers for ALARA program personnel

B. Applicable organization charts

C. Copies of audits, self-assessments, and LERs, written since date of last inspection,

focusing on ALARA

D. Procedure index for ALARA Program

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews

the procedure indexes.

• ALARA Program

• ALARA Committee

• Radiation Work Permit Preparation

F. A summary list of corrective action documents (including corporate and subtiered

systems) written since date of last inspection March 20, 2014, related to the ALARA

program. In addition to ALARA, the summary should also address Radiation Work

Permit violations, Electronic Dosimeter Alarms, and RWP Dose Estimates

NOTE: The lists should indicate the significance level of each issue and the search criteria

used. Please provide documents which are searchable.

G. List of work activities greater than 1 rem, since date of last inspection.

• Include original dose estimate and actual dose.

H. Site dose totals and 3-year rolling averages for the past 3 years (based on dose of

record)

I. Outline of source term reduction strategy

J. A major focus of this inspection will be the results of the power upgrade outage, please

provide the following:

• Annual ANO ALARA Report for 2014

• Last post Refueling-Outage Reports (Units 1&2)

• List of ALARA Package that Exceeded the Original Dose Projections

• Provide Written Justifications if Dose were Exceeded by 50 percent & 5 Person-

Rem

A-2

2. Occupational Dose Assessment (Inspection Procedure 71124.04) to be reviewed:

Date of Last Inspection: March 20, 2014. This part of the inspection will be

conducted by John ODonnell, and items needed are as follows

A. List of contacts and telephone numbers for the following areas:

• Dose Assessment personnel

B. Applicable organization charts

C. Audits, self assessments, vendor or NUPIC audits of contractor support, and LERs

written since date of last inspection March 20, 2014, related to:

• Occupational Dose Assessment

D. Procedure indexes for the following areas:

• Occupational Dose Assessment

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

• Radiation Protection Program

• Radiation Protection Conduct of Operations

• Personnel Dosimetry Program

• Radiological Posting and Warning Devices

• Air Sample Analysis

• Performance of High Exposure Work

• Declared Pregnant Worker

• Bioassay Program

F. List of corrective action documents (including corporate and subtiered systems) written

since date of last inspection March 20, 2014, associated with:

• NVLAP accreditation

• Dosimetry (TLD/OSL, etc.) problems

• Electronic alarming dosimeters

• Bioassays or internally deposited radionuclides or internal dose

• Neutron dose

NOTE: The lists should indicate the significance level of each issue and the search criteria

used.

G. List of positive whole body counts since date of last inspection March 20, 2014, names

redacted if desired

H. Part 61 analyses/scaling factors

I. The most recent National Voluntary Laboratory Accreditation Program (NVLAP)

accreditation report on the licensee or dosimetry vendor, as appropriate

Please provide this information to me by June 15, 2015; thank you in advance.

A-3