IR 05000313/2019011

Biennial Problem Identification and Resolution Inspection Report 05000313/2019011 and 05000368/2019011

ML19276E481
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/02/2019
From:	Geoffrey Miller Division of Reactor Safety IV
To:	Richard Anderson Entergy Operations
Azua R
References
IR 2019011
Download: ML19276E481 (12)

Text

ber 2, 2019

SUBJECT:

ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000313/2019011 AND 05000368/2019011

Dear Mr. Anderson:

On August 22, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed a biennial problem identification and resolution inspection at your Arkansas Nuclear One Units 1 and 2, and discussed the results of this inspection with Mr. Brian Patrick and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

The NRC inspectors did not identify any finding or violation of more than minor significance. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Geoffrey B. Miller, Deputy Director Division of Reactor Safety Docket Nos. 05000313 and 05000368 License Nos. DPR-51 and NPF-6

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000313 and 05000368 License Numbers: DPR-51 and NPF-6 Report Numbers: 05000313/2019011 and 05000368/2019011 Enterprise Identifier: I-2019-011-0002 Licensee: Entergy Operations, Inc.

Facility: Arkansas Nuclear One, Units 1 and 2 Location: Russellville, Arkansas Inspection Dates: August 5, 2019, to August 22, 2019 Inspectors: I. Anchondo-Lopez, Reactor Inspector R. Azua, IPAT, Acting Team Leader P. Jayroe, Reactor Inspector T. Sullivan, Resident Inspector Approved By: Geoffrey B. Miller Deputy Director Division of Reactor Safety Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Arkansas Nuclear One, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations No findings or violations of more than minor significance were identified.

Additional Tracking Items None

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs)in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.

Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)

The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety-conscious work environment (SCWE).

• Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems.

• Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.

• Safety-Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a SCWE.

INSPECTION RESULTS

Assessment 71152B Effectiveness of Problem Identification: Based on the samples reviewed, the team determined that the licensee's performance in this area adequately supported nuclear safety. Overall, the team found that the licensee was identifying and documenting problems at an appropriately low threshold that supported nuclear safety. On average, the licensee was identifying and documenting approximately 1360 Condition Reports (CRs) per month.

Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the licensee was appropriately prioritizing and evaluating issues to support nuclear safety. Of the samples reviewed, the team found that the licensee correctly characterized each condition report as to whether it represented a condition adverse to quality, and then prioritized the evaluation and corrective actions in accordance with program guidance.

Effectiveness of Corrective Actions: Overall, the team concluded that the licensee's corrective actions supported nuclear safety. Specifically, Arkansas Nuclear One, Units 1 and 2, developed effective corrective actions for the problems evaluated in the corrective action program and generally implemented these corrective actions in a timely manner commensurate with their safety significance. However, the team did identify some CRs that were difficult to follow or where it was not clear that the corrective actions were addressed. Ultimately, it was determined that the corrective actions were all completed appropriately, but that the documentation could have been better. It was noted by the team that these examples were for CRs written in 2016 and 2017. More recent CRs appeared to be better written with a clear line of sight as to how the corrective actions were addressed.

Corrective Action Program Assessment: Based on the samples reviewed, the team determined the licensee's corrective action program complied with regulatory requirements and self-imposed standards, and the licensee's implementation of the corrective action program adequately supported nuclear safety. The team found that management's oversight of the corrective action program process was effective.

Observation: Operating Experience, Self-Assessments, and Audit Assessment 71152B Operating Experience: The team reviewed a variety of sources of operating experience including Part 21 notifications and other vendor correspondence, NRC generic communications, and publications from various industry groups including Institute of Nuclear Power Operations (INPO) and Electric Power Research Institute (EPRI). The team determined that Arkansas Nuclear One, Units 1 and 2, is adequately screening and addressing issues identified through operational experience that apply to the station and that this information is evaluated in a timely manner once it is received.

Self-Assessments and Audit Assessment: The team reviewed a sample of the licensee's departmental self-assessments and audits to assess whether they regularly identified performance trends and effectively addressed them. The team also reviewed audit reports to assess the effectiveness of assessments in specific areas. Overall, the team concluded that the licensee had an adequate departmental self-assessment and audit process.

Observation: Safety-Conscious Work Environment Assessment (SCWE) 71152B Safety-Conscious Work Environment: The team interviewed approximately forty individuals in eight group interviews. The purpose of these interviews was

(1) to evaluate the willingness of your staff to raise nuclear safety issues, either by initiating a CR or by another method;

(2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems; and

(3) to evaluate your SCWE. The focus group participants included personnel from Security, Radiation Protection, Projects, and Instrumentation and Controls. Overall, Arkansas Nuclear One, Units 1 and 2, has an adequate SCWE.

Willingness to Raise Nuclear Safety Issues: In most focus groups, the team found no evidence of challenges to the SCWE. Individuals in these groups expressed a willingness to raise nuclear safety concerns and other issues through at least one of the several means available. However, the team found some work environment challenges in the Security Department. Through interviews with the staff members, the team identified a significant decline in morale that appears to permeate throughout the Security Department work environment. This degradation in morale appears to be caused by excessive overtime. The team brought this observation to senior plant managements attention, who were aware of many of the issues. While not currently affecting the SCWE, the team discussed with station management that continued degradation of staff morale could negatively impact staff performance. Specifically, distracted people are more likely to make mistakes.

Overall, the team concluded that all work groups at Arkansas Nuclear One, Units 1 and 2, maintained a healthy SCWE. However, morale issues in the Security Department may have a negative effect on staff performance and potentially on plant safety.

EXIT MEETINGS AND DEBRIEFS

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

On August 22, 2019, the inspectors presented the biennial problem identification and resolution inspection results to Mr. B. Patrick and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Corrective CR-ANO-X- 1-2015-00631, 1-2015-01110, 1-2016-00673, 1-2016-03526,

Action XXXX-XXXXX 1-2016-04473, 1-2016-04833, 1-2017-02109, 1-2017-02512,

Documents 1-2017-02518, 1-2017-03143, 1-2017-03472, 1-2017-03537,

1-2017-03673, 1-2018-00052, 1-2018-00053, 1-2018-00180,

1-2018-00181, 1-2018-00182, 1-2018-00530, 1-2018-00733,

1-2018-00851, 1-2018-00977, 1-2018-00999, 1-2018-01260,

1-2018-01348, 1-2018-01351, 1-2018-01408, 1-2018-01495,

1-2018-01610, 1-2018-01792, 1-2018-01959, 1-2018-02240,

1-2018-02282, 1-2018-02561, 1-2018-02821, 1-2018-02824,

1-2018-02845, 1-2018-03238, 1-2018-03540, 1-2018-03567,

1-2018-03614, 1-2018-03632, 1-2018-03729, 1-2018-03754,

1-2018-03930, 1-2018-04294, 1-2018-04314, 1-2018-04376,

1-2018-05007, 1-2018-05186, 1-2018-05187, 1-2018-05188,

1-2018-05206, 1-2018-05206, 1-2018-05244, 1-2018-05244(1),

1-2018-05311, 1-2018-05360, 1-2019-00141, 1-2019-00219,

1-2019-00290, 1-2019-00795, 1-2019-01017, 1-2019-01073,

1-2019-01073(1), 1-2019-01222, 1-2019-01224, 2-2002-02040,

2-2006-00318, 2-2008-01439, 2-2008-01763, 2-2010-00036,

2-2010-02793, 2-2010-02863, 2-2010-02865, 2-2012-02609,

2-2014-03154, 2-2015-00793, 2-2016-00789, 2-2016-00946,

2-2016-01071, 2-2016-04263, 2-2016-04277, 2-2017-03161,

2-2017-03337, 2-2017-05291, 2-2017-05330, 2-2017-05335,

2-2017-05335(1), 2-2017-05335(2), 2-2017-05335(3),

2-2017-06020, 2-2017-06114, 2-2018-00425, 2-2018-00867,

2-2018-00868, 2-2018-01418, 2-2018-02045, 2-2018-02545,

2-2018-03171, 2-2018-03412, 2-2018-03431, 2-2018-03442,

2-2018-03454, 2-2018-03454(1), 2-2018-03601, 2-2018-03750,

2-2018-04556, 2-2019-00430, 2-2019-00432, 2-2019-00780,

2-2019-00856, 2-2019-00863, 2-2019-00935, 2-2019-00936,

2-2019-00937, 2-2019-00938, 2-2019-00948, 2-2019-00949,

2-2019-00951, 2-2019-00952, 2-2019-00953, 2-2019-00954,

2-2019-00955, 2-2019-00956, 2-2019-00957, 2-2019-00958,

Inspection Type Designation Description or Title Revision or

Procedure Date

2-2019-00959, 2-2019-01073, 2-2019-01263, C-2012-01591,

C-2015-03033, C-2016-00614, C-2017-00203, C-2017-03180,

C-2017-04123, C-2017-04125, C-2017-04482, C-2017-04495,

C-2017-04517, C-2017-04759, C-2018-00299, C-2018-00495,

C-2018-00717, C-2018-01121, C-2018-01465, C-2018-01484,

C-2018-01846, C-2018-01846(1), C-2018-01928,

C-2018-02045, C-2018-02053, C-2018-02902, C-2018-03034,

C-2018-03052, C-2018-03070(1), C-2018-03210,

C-2018-03443, C-2018-03597, C-2018-03735, C-2018-04246,

C-2018-04316, C-2018-04349, C-2018-04570, C-2018-04572,

C-2019-00535(1), C-2019-01406, C-2019-02144,

C-2019-02193, C-2019-02894

Drawings 2HBC-68-1 Large Pipe Isometric Service Water Piping from Loop 1 Header

to Penetration Valve 2CV-1511-1

2HCC-313-1 Large Pipe Isometric Service Water Piping from 2VE-IB to

Service Water Header #2

2HCC-314-1 Large Pipe Isometric Service Water from Control Room

Emergency Chiller 2VE-1B to 2K-4B Heat Exchanger

CBV-A%-10- 1 Check Valve Sch 40 Socket Weld Ends, ANSI Class 600

0011

Piping & Instrumentation Diagram Service Water System, 10

M-2210

Unit 2

M-507 Instrument Line Class Specification

ULD-2-SYS-10 ANO Unit 2 Service Water System

Miscellaneous 6030.109 Installation of Electrical Cable & Wire 13

Procedures 1000.006 Procedure Control 73

1104.023 Diesel Oil Transfer Procedure 38

1601.505 Processing of Spent Radioactive Resin 18

1903.069 Equipment Important to Emergency Response 09

2104.029 Service Water System Operations 115

CEP-NDE-0965 Visual Welding Inspections ASME, ANSI B31.1 06

CEP-WP-003 Qualification and Control of Welders 06

CEP-WP-GWS-1 General Welding Standard ASME/ANSI 03

COPD-024 Risk Assessment Guidelines 67

EN-EC-100 Employee Concerns Program 10/11

EN-FAP-LI-001 Performance Improvement Review Group (PRG) Process 13

EN-LI-102 Corrective Action Program 36

EN-LI-104 Self-Assessment and Benchmark Process 13/14

EN-LI-118 Cause Evaluation Process 27/29

EN-LI-121 Trending and Performance Review Process 23/25

EN-OE-100 Operating Experience Program 28/32

EN-OP-104 Operability Determination Process 16

EN-OP-115 Conduct of Operations 25

EN-PL-100 Nuclear Excellence Model 09

EN-PL-187 Safety-Conscious Work Environment (SCWE) Policy 02

EN-PL-190 Maintaining a Strong Safety Culture 04

EN-QV-109 Audit Process 35

EN-TQ-114 Licensed Operator Requalification Training Program 11

EN-WM-102 Work Implementation and Closeout 10

OP-1032.036 Service Water Piping Leak Evaluation and Monitoring 05

OP-1102.015 Filling and Draining the Fuel Transfer Canal 44

OP-1104.002 Makeup and Purification System Operation 89

OP-1106.016 Condensate, Feedwater, and Steam System Operations 76

OP-1203-025 Natural Emergencies 68

OP-1402.240 Inspection of Watertight Hatches 01

OP-1903.010 EAL Classification 56/57

OP-1903.069 Equipment Important to Safety 68

OP-2104.036 Emergency Diesel Generator Operations 98

Self- LO-ALO-2018- Self-Assessment - Radiation Safety Hazard Assessment, 08/05/2019

Assessments 00063 Airborne Controls, and Performance Indicators

QA-10-2018- 2018 QA Audit of Maintenance 07/13/2018

ANO-1

QA-14/15-2017- 2017 QA Audit of Combined Radiation Protection and 11/14/2017

ANO-01 Radwaste

QA-3-2019-ANO- 2019 QA Audit of Corrective Action Program at Arkansas 06/19/2019

Nuclear One

QA-8-2019-ANO- 2019 QA Audit of Engineering Programs 04/11/2019

Work Orders WO-XXXXXX 150817, 260381, 261219, 379285, 379287, 457963, 462301,

461547-1, 503751, 506252, 521657-01, 521759

WR-XXXXXX 421140, 421141

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