ML18115A417

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NRC Integrated Inspection Report 05000313/2018001 and 05000368/2018001 and Independent Spent Fuel Storage Installation Inspection Report 07200013/2018001
ML18115A417
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 04/25/2018
From: O'Keefe N F
NRC/RGN-IV/DRP/RPB-E
To: Anderson R L
Entergy Operations
O'Keefe C F
References
Download: ML18115A417 (42)


See also: IR 05000313/2018001

Text

April 25, 2018

Mr. Richard L. Anderson

Site Vice President

Entergy Operations, Inc.

Arkansas Nuclear One

1448 S.R. 333

Russellville, AR 72802

SUBJECT: ARKANSAS NUCLEAR ONE

- NRC INTEGRATED INSPECTION REPORT 05000 313/2018001 AND 05000368/2018001 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION INSPECTION REPORT 07200013/2018001

Dear Mr. Anderson: On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Arkansas Nuclear One facility

, Units 1 and 2. On April 5 , 2018 , the NRC inspectors discussed the results of this inspection with Mr. John Kirkpatrick, General Manager of Plant Operations, and other members of your staff.

On April 18, 2018, the NRC inspectors exited to modify the characterization of one finding

with Ms. Stephanie Pyle, Regulatory Assurance Manager. The results of this inspection are documented in the enclosed report.

NRC inspectors document

ed two finding s of very low safety significance (Green) in this report. Both of these finding s involved a violatio

n of NRC requirements.

Additionally, NRC inspectors documented a licensee

-identified violation, which was determined to be of very low safety significance (Green)

, in this report. The NRC is treating these violation s as non-cited violation

s (NCV s) consistent with Section

2.3.2.a of the Enforcement Policy.

If you contest the violation

s or significance of the NCV

s , you should provide a response within

30 days of the date of this inspection report, with the basis for your denial, to the U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC

20555-0001; with copies to the Regional Administrator, Region

IV; the Director, Office of Enforcement; and the NRC resident inspector at the 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 U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555

-0001; with copies to the Regional Administrator, Region

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

R. Anderson

2 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/ Neil O'Keefe

, Chief Branch E Division of Reactor Projects

Docket Nos. 50

-313 and 50-368 License Nos. DPR-51 and NPF-6 Enclosure:

Inspection Report 05000313/2018001 and 05000368/2018001

and 07200013/2018001

w/ Attachment s: 1. Documents Reviewed

2. Occupational Radiation Safety Inspection

Request for Information

ML18115A41

7 SUNSI Review

By: NFO/rdr Non-Sensitive Sensitive Publicly Available

Non-Publicly Available

Keyword: NRC-002 OFFICE ASRI:DRP/E

SRI:DRP/E RI:DRP/E RI:DRP/E BC:DRS/EB1

BC:DRS/EB2

NAME PSmagacz CHenderson

MTobin TSullivan TFarnholtz

JDrake SIGNATURE /RA/ /RA/ /RA/ /RA/ /R A/ /RA/ DATE 4/23/2018 4/20/2018 4/20/2018 4/20/2018 4/24/2018 4/24/18 OFFICE BC:DRS/OB BC:DRS/PSB2

TL:DRS/IPAT

BC:FCDB BC:DRP/E NAME VGaddy HGepford GGeorge RKellar NO'Keefe SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ DATE 4/25/18 4/24/18 4/24/2018 4/24/18 4/25/18

Enclosure U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Numbers: 05000313; 05000368; and 07200013

License Numbers: DPR-51; NPF-6 Report Numbers: 05000313/2018001; 05000368/2018001; and 07200013/2018001

Enterprise Identifier:

I-2018-001-0005 Licensee: Entergy Operations, Inc.

Facility: Arkansas Nuclear One, Units

1 and 2 , and Independent

Spent Fuel Storage Installation

Location: Junction of Highway

64 West and Highway

333 South Russellville, Arkansas Inspection Dates: January 1, 2018 to March 31, 2018 Inspectors:

C. Henderson, Senior Resident Inspector

P. Smagacz, Acti

ng Senior Resident Inspector

T. Sullivan, Resident Inspector

M. Tobin, Resident Inspector

L. Brookhart, Senior Inspector

N. Greene, Ph.D., Senior Health Physicist

J. O'Donnell, CHP, Health Physicist

Approved By:

N. O'Keefe , Branch Chief

2 SUMMARY The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensee's performance by conducting an integrated inspection at Arkansas Nuclear One

, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC's program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html

for more information.

NRC-identified

and self-revealed findings and violations, and additional items are summarized in the table

s below. A licensee-identified

, non-cited violation

is documented in report

S ection 71124.01. List of Findings and Violations

Failure to Establish Adequate Criteria for Flood Seal Testing

Cornerstone

Significance

Cross-cutting Aspect Inspection Procedure Mitigating Systems Green Finding NCV 05000313/2018001-01 and 05000368/2018001

-01 Closed [H.1 2] - Avoid Complacency

71111.01 - External Flooding The inspectors identified a Green finding and associated non

-cited violation of Unit

1 Technical Specification 5.4.1.a and Unit

2 Technical Specification 6.4.1.a for the licensee's failure to establish the criteria for ensuring the necessary conditions existed for a successful test of hatch flood seals. Specifically, Procedure

OP 1402.240, "Inspection of

Watertight Hatches," Revision 1, did not contain adequate guidance to ensure that the auxiliary building was at a lower pressure than the turbine building such that puffing smoke on the turbine building

side would allow a seal leak to be detectable.

Failure to Preplan and Perform Service Water Pre

-Screen Maintenance

Cornerstone

Significance

Cross-cutting Aspect Inspection Procedure Mitigating Systems Green Finding NCV 05000368/2018001

-02 Closed [H.12] - Avoid Complacency

71152 - Problem Identification

and Resolution

The inspectors reviewed a self

-revealed, non-cited violation and associated finding of Arkansas Nuclear One

, Unit 2 , Technical Specification 6.4.1.a, for the licensee's failure to properly preplan maintenance that can affect the performance of safety

-related equipment. Specifically, the licensee failed to properly preplan pre-screen cleaning maintenance, causing the train B service water system to become inoperable.

Additional Tracking Item s Type Issue number

Title Inspection Procedure Status URI 7200013/20 12 00 1-0 2 Validation of the

ANO data collected during the thermal validation test and used in the Holtec analysis

60855.1 Closed

3 Type Issue number

Title Inspection Procedure Status URI 7200013/2012001

-03 Applicability of the ANO thermal validation test results to other HI

-STORM 100 overpack configurations

60855.1 Closed LER 05000313/2016-002-00 Tornado Missile Vulnerability Resulting in Condition Prohibited By Technical Specifications

71153 Closed

4 PLANT STATUS

Unit 1 began the inspection period at full power. On March 24 , 2018, the unit was shut down to begin Refueling Outage 1R 27. Unit 2 began the inspection period at full power. On January

14 , 2018, the unit reduced power to 83 percent to perform planned condenser water box cleaning. The unit was returned to rated thermal power on January

19 , 2018. INSPECTION SCOPE

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

-rm/doc-collections/insp

-manual/inspection

-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter

(IMC) 2515, "Light

-Water Reactor Inspection Program - Operations Phase." The inspectors performed plant status activities described in IMC 2515, Appendix

D, "Plant Status," and conducted routine reviews using IP

71152, "Problem Identification and Resolution." The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather

(1 Sample) The inspectors evaluated readiness for seasonal extreme weather conditions prior to

the onset of seasonal cold temperatures

. Unit 1 and Unit

2 diesel fuel oil vault

on January 30 , 2018 Un it 2 emergency diesel generator

2 on January 30, 2018 Alternate

ac diesel generator

on January 30 , 2018 Unit 1 and Unit

2 emergency cooling pond

on January 30 , 2018 External Flooding

(1 Sample) The inspectors

evaluated readiness to cope with external flooding

on March 16, 2018. A finding associated with this inspection is documented in the Inspection Results section below.

5 71111.04 - Equipment Alignmen

t Partial Walkdown

(4 Samples) The inspectors evaluated system configuration

s during partial walkdowns of the following systems/trains

(1) Unit 2 train A emergency feedwater system during planned maintenance of train

B emergency feedwater system on February

7, 2018 (2) Unit 2 swing service water pump

B aligned to the emergency cooling pond during intake structure pre

-screen cleaning and maintenance on February

22, 2018 (3) Un it 2 emergency diesel generator

2 ventilation system on March

2 , 2018 (4) Unit 1 temporary reactor vessel level identification system on March

28, 2018 Complete Walkdown

(1 Sample) The inspectors

evaluated system configuration

s during a complete walkdown of the Unit 2 service water

system on March 14, 2018. 71111.05 - Fire Protection

Annual/Quarterly

Quarterly Inspection

(4 Samples) The inspectors evaluated fire protection program implementation in the following selected areas: (1) Unit 2 auxiliary building corridor

210 9 temporary safety

-related battery heating, Fire Area MM, Fire Zone

2103-V , on January

30, 2018 (2) Unit 1 cable spreading room, Fire Area

G, Fire Zone

97-R , on January

31, 2018 (3) Unit 2 upper south

piping penetration room, Fire Area

EE-L , Fire Zone 2084-DD, on February 8, 2018 (4) Unit 2 lower south

piping penetration room, Fire Area

EE-L, Fire Zon

e 2055-JJ, on February 8, 2018 Annual Inspection

(1 Sample) The inspectors

evaluated fire brigade performance in the Unit 1 control room for a simulated fire emergency feedwater pump room and the Unit 2 turbine deck for a simulated fire in the turbine generator on January 4, 2018 , and March 0 9 , 2018.

6 71111.06 - Flood Protection Measures

Internal Flooding

(1 Sample) The inspectors evaluated internal flooding mitigation protections in the Unit

2 emergency feedwater room floor drain system on March 16, 2018. Cables (1 Sample) The inspectors

evaluated cable submergence protection

in Manhole 8 on March 1, 2018. 71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification

(2 Samples) (1) The inspectors

observed and evaluated Unit 1 simulator training for operating crews on reactor shutdown and decay heat removal on February 22, 2018. (2) The inspectors observed and evaluated Unit

2 simulator training for operating crews on reactor coolant pump motor fire and security related events on February

22, 2018. Operator Performance

(2 Samples) (1) The inspectors

observed and evaluated Unit 2 return to near 100

percent power following condenser cleaning on

January 18, 2018. (2) The inspectors observed and evaluated Unit

1 reactor shutdown for commencing

Refuel Outage 1R27 on March

23 , 2018. 71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness

(3 Samples) The inspectors evaluated

the effectiveness of routine

maintenance activities associated with the following equipment

and/or safety significant functions

(1) Unit 1 rod control system

on January

31, 2018 (2) Unit 2 service water system on March 6, 2018 (3) Internal and external flood seals on March 16, 2018 Quality Control

(1 Sample) The inspectors evaluated maintenance and quality

control activities associated with the following equipment performance issues:

(1) Unit 2 control element assembly system

on January

31, 2018 71111.13 - Maintenance Risk Assessments and Emergent Work Control

(6 Samples) The inspectors evaluated the risk assessments for the following planned and emergent work activities

(1) Unit 2 planned work activities for control element assembly

5 repair on January 5, 2018

7 (2) Unit 2 emergent work activities

for emergency diesel generator

2 on January

10, 2018 (3) Unit 2 emergent work activities for service water pump

A and C strainer cleaning following high differential pressure alarm during pre

-screen cleaning on January 19, 2018 (4) Unit 1 and Unit

2 planned work activities for startup transformer

1 and 3 outage for autotransformer insulator repair on February

2, 2018 (5) Unit 2 planned work activities for service water bay pre

-screen cleaning and maintenance on February

22, 2018 (6) Unit 2 service water pre

-screen cleaning

on February 22, 2018 71111.15 - Operability Determinations and Functionality Assessments

(6 Samples) The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 1 operability determination for auxiliary building tornado missile protection wall

missing rebar on January 18, 2018 (2) Unit 1 operability determination for emergency feedwater control valve, CV

-2646, stroke time outside operability limits on January

22, 2018 (3) Unit 2 operability determination for emergency diesel generator

2 relay failure and automatic start function for

containment coolers on January

24, 2018 (4) Unit 1 and Unit

2 operability determination for emergency cooling pond during cold weather impact of safety

-related pumps

operating oil temperature

on January

31, 2018 (5) Unit 1 and Unit

2 operability determination for 500

kV offsite circuit autotransformer damaged insulator on February

9, 2018 (6) Unit 2 functional determination emergency feedwater system room floor drain system on March 16, 2018 71111.18 - Plant Modifications

(2 Samples) The inspectors evaluated the following temporary or permanent modifications:

(1) Unit 2 temporary modification for lifting leads for control element assembly

4 for degraded upper gripper coils on January

5 , 2018 (2) Unit 2 temporary battery room heating on January

30, 2018 71111.19 - Post Maintenance Testing (4 Samples) The inspectors evaluated the following post maintenance

tests: (1) Unit 2 replacement of service water pump

A and C strainers on January

20, 2018

8 (2) Unit 1 auxiliary building hatch HTC

-492 smoke testing following resin transfer on February 14, 2 018 (3) Unit 2 motor drive

n emergency feedwater pump flow transmitter calibration due to the transmitter reading low out of range on February

20, 2018 (4) Unit 1 temporary reactor vessel level indication

due valve, RC-1, repair on March 28, 2018 71111.20 - Refueling and Other Outage Activities

(Partial Sample) The inspectors evaluated Unit 1 Refueling Outage 1R27 activities

from March 24, 2018 , to March 31, 2018. The inspectors completed inspection procedure Sections

03.01.a and 03.01.c. 71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests:

Routine (3 Samples) (1) Unit 1 emergency feedwater solenoid operated control valve, CV

-2646, establishment of stroke time reference value and

acceptance criteria on January

25, 2018 (2) Unit 1 and Unit 2 verified correct breaker alignment and indicated power availability for the 161 kV offsite circuited with the 500 kV offsite inoperab

le during autotransformer insulator repair

on February

2, 2018 (3) Unit 1 train A reactor protection system and rod control system

ac breaker surveillance trip testing on February

27, 2018 I n-service (1 Sample) (1) Unit 2 service water motor operated valve , 2 CV-1435-1 , service water inlet

to train A shutdown heat exchanger on March 15, 2018 Reacto r Coolant System Leak Detectio n (1 Sample) (1) Unit 1 small increase of unidentified leakage

on March 2, 2018 RADIATION SAFET

Y 71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard

Assessment

(1 Sample) The inspectors

evaluated radiological hazards assessments and controls

. Instructions to Workers

(1 Sample) The inspectors evaluated worker instructions

.

9 Contamination and Radioactive Material

Control (1 Sample) The inspectors evaluated contamination and radioactive material controls

. Radiological Hazards Control and Work Coverage

(1 Sample) The inspectors

evaluated radiological hazards control and work coverage

. High Radiation Area and Very High Radiation Area Controls

(1 Sample) The inspectors evaluated risk

-significant high radiation area and very high radiation area controls. Radiation Worker Performance and Radiation Protection Technician Proficiency

(1 Sample) The inspectors evaluated radiation worker performance and radiation protection technician proficiency

. 71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls

Implementation of ALARA and Radiological Work Controls

(1 Sample) The inspectors reviewed ALARA practices and radiological work controls by reviewing the following activities and/or work packages:

(1) 2017-1070, c ore bore National Fire Protection Association (NFPA) 805 project and support activities

(2) 2018-1414, as low as reasonable achievable (ALARA) activities during 1R27

(3) 2018-1420, scaffold installation/removal non

-Locked High Radiation Area s - 1R27 (4) 2018-1430, r eactor disassembly, reassembly, and support activities

(5) 2018-1900, emergent maintenance activities during 1R27

Radiation Worker Performance

(1 Sample) The inspectors

evaluated radiation worker and radiation protection technician performance

. OTHER ACTIVITIES

- BASELINE 71151 - Performance Indicator Verification

The inspectors verified licensee performance

indicators

submittals

listed below: (8 Sample s) (1) IE01: Unplanned Scrams per 7000 Critical Hours Sample, Unit 1 and Unit

2, (January 1, 2017, through Decemb er 31, 2017) (2) IE03: Unplanned Power Changes per

7000 Critical Hours Sample, Unit 1 and Unit

2, (January 1, 2017, through December

31, 2017)

10 (3) IE04: Unplanned Scrams with

Complications

Sample , Unit 1 and Unit

2, (January 1, 2017, through December 31, 2017) (4) OR01: Occupational

Exposure Control Effectiveness

Sample (April 1 , 2017, through

March 30 , 2018) (5) PR01: Radiological

Effluent Technical Specifications/

Offsite Dose Calculation

Manual (RETS/ODCM)

Radiological

Effluent Occurrences

Sample (April 1, 2017, through March 30, 2018) 71152 - Problem Identification and Resolution

Annual Follow

-up of Selected Issue s (1 Sample) The inspectors reviewed the licensee's implementation of its corrective action

program related to

the following issues:

(1) Unit 2 train B service water inoperable due to strainer high differential pressure during pre-screen cleaning following winter shad run on March

27 , 2018 A finding associated with this inspection is documented in the Inspection Results section below. 71153 - Follow-up of Events

and Notices of Enforcement Discretion

Events (2 Samples) (1) The inspectors evaluated

licensee's response to Unit 2 entry into loss of service water abnormal operating procedure due to service water pump

A and C strainer high differential pressure

alarm during

pre-screen cleaning

on January 19, 2018. (2) The inspectors evaluated licensee's response to Unit

1 and Unit

2 cyber security issue

s on the business network

on February

6, 2018. Licensee Event Reports (LERs) (1 Sample) The inspectors evaluated the following

licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx

(1) LER 050003 13/201 6-00 2-00, Tornado Missile Vulnerability Resulting in Condition Prohibited By Technical Specifications, on February 5, 2018 OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT

AND ABNORMAL 60855.1 - Operation of an Independent Spent Fuel Storage Installation

at Operating Plants

The inspectors evaluated the licensee's

operation of the independent spent fuel storage

installation

(ISFSI) from October

30 to November

2, 2017, on-site at ANO, and conducted an in-office review of additional documentation related to licensee's maintenance of their cask handling crane until January

2018.

11 The ANO ISFSI consisted of four ISFSI pads. ANO had loaded

24 canisters of the Energy Solutions

ventilated

storage cask (VSC) VSC

-24 design (Certificate of Compliance

No. 1007) from 1996 to 2003. Since that time, ANO had been loading HI

-STORM 100S Versi on C overpacks. ANO's ISFSI contained a total of 57

HI-STORM overpacks with

32 MPC-24 canisters and 25

MPC-32 canisters, at the time of the routine inspection. ANO was currently loading canisters to the Holtec Certificate of Compliance

1014, Amendment

5 , and Final Safety Analysis Report (FSAR), Revision

7. The ISFSI activities specifically reviewed during the on

-site inspection and the subsequent

in-office review included:

(1) Evaluated and observed fuel selection and fuel loading operations.

(2) Reviewed the licensee's loading, processing, and heavy load procedures associated with their current dry fuel storage campaign.

(3) Reviewed licensee's corrective action program implementation for ISFSI operations since the last routine ISFSI inspection which was completed in December

2015. (4) Reviewed quality assurance (QA) program implementation, including recent QA audits, surveillances, receipt inspection, and quality control activities.

(5) Reviewed documentation related to technical specification (TS) required operational surveillance activities and Final Safety Analysis Report (FSAR) required annual maintenance activities.

(6) Reviewed the licensee's radiological monitoring data for the calendar years

2014, 2015, and 2016.

(7) Reviewed spent fuel documentation for the canisters loaded since the last routine

ISFSI inspection (Holtec Canister

48-57) to confirm the fuel met all TS requirements

for storage and transportation.

(8) Reviewed annual maintenance activities for heavy lifting components which included special lifting devices and the

site's cask handling crane (Auxiliary Building

L-3 crane). (9) Reviewed all 72.48 safety evaluations/screenings for changes made to the licensee's ISFSI operations in accordance with Inspection Procedure

60857 since the last routine ISFSI inspection.

(10) Reviewed all changes made to the licensee's 72.212

Report (Revision

10) in accordance with Inspection Procedure

60856.1 since the last routine ISFSI inspection.

Additionally, inspectors closed two

unresolved

items (URI s) from a routine ISFSI inspection conducted i

n 2012 (see Inspection Results).

12 INSPECTION RESULTS

Failure to Establish Adequate Criteria for Flood Seal

Testing Cornerstone

Significance

Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000313/2018001

-01 and 05000368/2018001

-01 Closed [H.1] - Resources 71111.01 - External Flooding The inspectors identified a Green finding and associated non

-cited violation of Unit

1 Technical Specification 5.4.1.a and Unit 2 Technical Specification 6.4.1.a for the licensee's failure to establish the criteria for ensuring the necessary conditions existed for a successful test of hatch flood seals

. Specifically, Procedure

OP 1402.240, "Inspection of Watertight Hatches," Revision

01, did not contain adequate guidance to ensure that the auxiliary building was at a lower pressure than the turbine building such that puffing smoke on the turbine building side would allow a seal leak to be detectable

. Description

As part of corrective actions to prevent recurrence for Yellow finding

05000313/2014009

-01 and 05000368/2014009

-01, the licensee improved the preventive maintenance for flood seals on hatches that prevented flood waters from external sources from entering the auxiliary building, where safety

-related accident mitigation equipment was located. These actions included a new testing protocol which established a pressure differential across the seal, then puffed chemical smoke around the seal and observ

ed for leaks. Known as a smoke test, this method require

s that air pressure inside the auxiliary

building be lower than turbine building

air pressure so that when smoke

is puffed around the outside of the seal, the smoke would be pulled into the lower pressure area on the other side, and leaks would be detectable.

On November

29, 2017 , as part of a Confirmatory Action Letter Inspection, NRC inspectors review ed corrective actions

and observed a smoke test of hatch 492. The inspector noted that test personnel had checked that the auxiliary building ventilation was in a normal alignment, but had assumed that this meant that

pressure was lower on the auxiliary building side of the hatch.

When the licensee agreed to measure the pressure on each side of the hatch, pressure was actually higher on the auxiliary building side such that leakage would not have been detectable.

Procedure OP 1402.240, "Inspection of Watertight Hatches," Revision

01, directed personnel to ensure negative ventilation in the auxiliary building prior to start. However, the procedure did not state how much pressure differential was needed or how this was to be measured. The inspector determined that all

six hatches that serve as flood barriers were previously tested using the inadequate procedure. Upon discovery, the licensee took action to ensure that a negative ventilation in the

auxiliary building would be established and verified as part of the procedure. When re

-tested, all hatches passed the smoke test.

Corrective Action (s): The corrective action was to make changes to the procedure to establish appropriate ventilation

line up and re-perform the smoke tests at all locations.

Corrective Action Reference

(s): Condition Report CR

-ANO-C-2017-04759

13 Performance Assessment:

Performance Deficiency: The licensee's failure to establish adequate prerequisite criteria for smoke testing flood seals on hatch es is a performance deficiency.

Screening: The performance deficiency is more than minor because

, if left uncorrected, it has the potential to become a more significant safety concern. Specifically, because Procedure OP 1402.240 did not have adequate instructions to ensure the appropriate ventilation lineup, hatch flood seals would always pass the test regardless of whether the seal would allow water to pass or not. Therefore, any flooding or pipe rupture could lead to water ingress into the Unit

1 and Unit

2 auxiliary buildings affecting the availability of mitigating equipment needed to respond to flooding

. This finding affects the Mitigating Systems Cornerstone.

Significance: The inspectors assessed the significance of the finding using

Inspection Manual Chapter 0609, Appendix

A, "The Significance Determination Process (SDP) for Findings At

-Power," dated June

19, 2012. The inspectors determined that the finding had very low safety significance (Green) because the equipment or

safety function was not completely failed or unavailable, and because the finding does not involve the total loss of any safety function, identified by the licensee through a probabilistic risk assessment (PRA), individual plant examination of external events (IPEEE), or similar analysis, that contributes to external event initiated core damage accident sequences. Specifically, since the hatches were confirmed to be leak tight after re

-testing, no actual loss of function occurred.

Cross-cutting Aspect: This finding has a cross

-cutting aspect in the area of human performance associated with avoiding complacency, because the individuals failed to verify that procedure prerequisites

were met rather than assume they are met based on general plant conditions.

Enforcement

Violation: Technical Specification 5.4.1.a for Unit 1 and Technical Specification 6.4.1.a for Unit 2 requires, in part, that written procedures be established, implemented, and maintained covering the applicable procedures recommended in

Appendix A to Regulatory Guide

1.33, "Quality Assurance Program Requirements," Revision 2, February

1978. Regulatory Guide 1.33, Appendix

A, Section

9.a, states that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

Contrary to the above , on November

29, 2017, the licensee failed to properly preplan and perform maintenance that can

affect the performance of safety

-related equipment in accordance with written procedures, document instructions, or drawings appropriate to the circumstances. Specifically, Procedure

1402.240, "Inspection of Watertight Hatches," Revision 01, failed to include adequate details needed to

not verify that the auxiliary building was at a lower pressure than the turbine building

prior to performing a smoke test

of the flood seal of hatch 492. Under the existing conditions, the test would have passed even with

a degraded seal. This condition had the potential to affect the performance of safety

-related mitigating equipment needed to respond to a flooding event

.

14 Disposition:

This violation is being treated as a non

-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy, because it was very low safety significance (Green) and was entered into the licensee's corrective action

program as Condition Report

CR-ANO-C-2017-04759. Failure to Preplan and Perform Service Water Pre

-Screen Maintenance

Cornerstone

Significance

Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000368/2018001

-0 2 Closed [H.12] - Avoid Complacency

71152 - Annual Follow-up of Selected Issues The inspectors reviewed a self

-revealed, non-cited violation and associated finding of Arkansas Nuclear One

, Unit 2 , Technical Specification 6.4.1.a, for the licensee's failure to properly preplan maintenance that can affect the performance of safety

-related equipment. Specifically, the licensee failed to properly preplan pre-screen cleaning maintenance, causing the train B service water system to become inoperable.

Description

On January

19, 2018, ANO Unit 2 was operating in Mode

1 and making preparations to clean the intake structure service water pre-screens in accordance with

Operating Procedure (OP)

2104.029, "Service Water System Operations," Change

109. Two operable trains of service water are required per Unit

2 Technical Specification 3.7.3.1, Service Water System while in Mode

1. The ANO Unit 2 service water system has stationary

pre-screens between the traveling screens and the pump

s that must be manually hoisted out of the flow stream to be cleaned. The configuration is such that debris can be knocked loose and fall back into the flow stream during cleaning and enter both running pumps.

The pre-screens are intended to catch small debris that was not removed by the traveling screen so that the strainer baskets located downstream of each pump do not get clogged. The discharge

strainer basket design does

not have a self

-cleaning feature.

Between January 16, 2018 , through dayshift January

18, 2018, the licensee was aware that they were experiencing a shad (fish) run in the intake canal. The pre-screen differential pressure (D/P) had been exhibiting a rising trend due to debris buildup. During this timeframe, the pre

-screen and traveling screen D/P went from 3.00

inches of water

to 6.75 inches of water. At 8:52

pm on January

18, 2018, the licensee received the service water high differential pressure alarm

and pre-screen D/P was 9.5

inches of water, with a procedural requirement to initiate action to clean the pre

-screens at 8

inches of water. Prior to the licensee cleaning the pre

-screens, D/P reached 18

inches of water. This rate of debris buildup was unusual considering most D/P effects on the screen are witnessed on ANO

Unit 1 screens and not ANO

Unit 2 screens. Based on past experience of slow build

-up of debris, the licensee delayed pre

-screen cleaning until 4:14

a.m. on January

19, 2018, to avoid having maintenance personnel

exceed fatigue management limits

. During the lifting and removal of the first pre-screen for cleaning, fish were observed to be falling off and entering the suction of the A (SW

-P-A) and C (SW

-P-C) service water pumps. As a result, the Unit 2 control room received SW

-P-A and SW-P-C discharge strainer high differential pressure (D/P) annunciators. The SW

-P-A discharge strainer D/P peaked at 12.8 psid, and the SW

-P-C discharge strainer D/P peaked at 24.1

psid. The licensee entered

15 abnormal Operating Procedure 2203.022, "Loss of Service Water," Revision

14 , and assessed the operability of

train A and B service water systems. The swing pump suction was aligned to the emergency cooling pond

and the pump started so that a second train of service water could be made available if needed.

Following an engineering evaluation, train

B service water system was declared inoperable due to exceeding the 20

psid operability limit for the SW

-P-C strainer; train

A service water system remained

operable throughout the event. Over the course of the rest of the day, the licensee manipulated the service water system to clean the rest of the pre

-screens and the service water pump discharge strainers

and reestablish train

B service water system

operability. The train

B service water system was declared operable at 10:10

p.m. on January 19, 2018, at which time the

"Loss of Service Water

" procedure was exited. The licensee's short term corrective action was to implement a standing order for service water pre-screens and traveling screens

that required operations personnel to log both pre

-screen and traveling screen D/P and clean traveling screens at least weekly and pre

-screens weekly. The licensee documented this issue in Condition Report CR

-ANO-C-2 018-00299. The inspectors noted that a similar event occurred

on August 19, 2016. The D/P on the train B service water pump strainer continued to rise until it reached the threshold at which the performance of an engineering

evaluation

was required to determine the operability of the B train of

service water. This high D/P was attributed to fouling of the strainer caused by pre

-screen cleaning activities

and delaying the start of the cleaning. Despite this

event, the same basic chain of events recurred

on January 19, 2018. The inspectors pointed out that the pre-screen design created an inherent risk of spilling debris into the open hole created by lifting the pre-screens. With both trains in a normal alignment, most of the debris would enter both pumps and begin to clog the discharge strainer. The inspectors questioned why this risk was not avoided by proactively aligning one or both trains to the emergency cooling pond. The licensee agreed to study this alternative as a possible corrective action.

Corrective Action (s): The immediate corrective action was to restore operability of the train

B service water system and institute a weekly pre

-screen cleaning regiment.

Corrective Action Reference

(s): Condition Report CR

-ANO-C-201 8-0 0299 Performance Assessment:

Performance Deficiency

The licensee's failure to properly preplan pre-screen cleaning maintenance that can affect the performance of safety

-related equipment is a performance deficiency.

As a result, the performance of both trains of the safety-related service water system were challenged, and train

B was rendered inoperable.

Screening: The performance deficiency was more than minor because it adversely affected the human performance attribute of the Mitigating Systems

Cornerstone and the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Specifically, the licensee's failure to properly preplan pre-screen cleaning maintenance resulted in the train B service water system being rendered inoperab l e. Significance: Using NRC Inspection Manual Chapter 0609, Appendix

A, "The Significance Determination Process (SDP) for Findings At

-Power," dated June

19, 2012, Exhibit

2, "Mitigating Systems Screening Questions," the inspectors determined that the finding had very low safety significance (Green) because it

was not a design deficiency; did not

16 represent a loss of system and/or function; did not represent an actual loss of function of at

least a single train for longer than its technical specification allowed outage time; and did not result in the loss of

a high safety

-significant, nontechnical specification train

. Cross-cutting Aspect: The finding had a cross

-cutting aspect in the area of

human performance associated with avoid complacency because the licensee did not plan for the inherent risk with cleaning the pre

-screens although cleaning of debris has previously challenged the service water system. Specifically, the licensee did not effectively plan pre

-screen cleaning maintenance to avoid system impacts, and did not consider the rate of increas e in pre-screen differential pressure due to the winter fish runs

in deciding when to start the cleaning

. Enforcement

Violation: Technical Specification 6.4.1.a requires, in part, that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix

A of Regulatory Guide

1.33, Revision

2, February

1978. Section

9.a of Regulatory Guide

1.33 , Appendix A , states that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

Contrary to the above, on January

19, 2018, the licensee failed to properly preplan and perform maintenance

as prescribed in Regulatory Guide

1.33. Specifically, the licensee failed to preplan the cleaning of Unit 2 service water pre

-screens prior to high debris loading of the screens, and failed to place the service water system into an alignment that would have avoided impacting the operability of this safety

-related system.

Disposition:

This violation is being treated as a non

-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy, because it was very low safety significance (Green) and was entered into the licensee's corrective action program as Condition Report

CR-ANO-C-2018-00299. Licensee Identified Non

-Cited Violation

71124.01 -Radiological Hazard Assessment and Exposure Controls

This violation of very low safety significant (Green) was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a

n on-cited violation, consistent with Section

2.3.2.a of the Enforcement Policy.

Violation:

Title 10 CFR 20.1501(a) requires that each licensee make or cause to be made surveys that may be necessary for the licensee to comply with the regulations in

10 CFR Part 20 , and that are reasonable under the circumstances to evaluate the magnitude and extent of radiation levels, concentrations

, or quantities of radioactive materials, and the potential radiological hazards that could be present.

Contrary to the above, on August 7, 2017, the licensee failed to make necessary surveys of the Unit 2 , 2T-15 tank room, that were reasonable to evaluate the magnitude and extent of radiation levels that could be present. Consequently, workers were allowed access to an area with dose rates up to

1000 millirem per hour at 30

cm without a proper briefing or oversight.

17 Significance: Using NRC Manual Chapter 0609, Appendix

C, "Occupational Radiation Safety Significance Determination Process," the inspectors determined the finding to be of very low

safety significance (Green) because:

(1) it was not associated with as low as is reasonably achievable (ALARA) planning or work controls; (2)

there was no overexposure; (3)

there was no substantial potential for an overexposure; and (4)

the ability to assess dose was not compromised.

Corrective Action Reference(s):

CR-ANO-2-2017-04634 and

CR-ANO-2-2017-05337 Unresolved Item

(Closed) Validation of the ANO data collected during the thermal validation test and used in the Holtec analysis.

URI 7200013/201

2001-02 60855.1 Description

During the routine ISFSI inspection conducted on October

29 - November 1, 2012, an unresolved item (URI) was identified and documented in the routine ISFSI NRC Inspection Report 050003 13/20120008, 05000368/2012008, and 07200013/2012001 (ADAMS Accession No

. ML13057A986)

. The Holtec International HI

-STORM 100 Certificate of Compliance (CoC) No.

1014, Condition 9 , required the performance of a one

-time thermal validation test on the first cask

that exceeded 20

kW to validate the

analytical methods and thermal performance predicted by the licensing basis thermal model as described in Chapter

4 of the Holtec HI

-STORM 100 FSAR. ANO was the first general licensee to load a canister exceeding 20

kW and, as such, was required to perform the thermal validation test in accordance with License Condition

9. During the NRC inspection in 2012, the inspectors identified that ANO had completed the test using instrumentation that had not been controlled or calibrated in accordance with ANO's

quality assurance program. The NRC identified this failure to follow the ANO's quality assurance program for the thermal validation test instrumentation as a

n on-cited violation of

10 CFR 72.164 (NCV

07200013/2012001

-01) consistent with Section

2.3.2 of the NRC Enforcement Policy. The validation of the data collected by the instrumentation used during the test was considered indeterminate until the licensee was able to demonstrate that the equipment was properly calibrated by a qualified vender on the licensee's approved vendor list. The resolution of this issue was tracked as an

unresolved

item (URI 07200013/2012001

-02). ANO took corrective actions to verify that the data from the measuring instruments was acceptable by sending the equipment to a qualified lab to verify the equipment was properly calibrated. ANO was able to verify the calibration of the resistance temperature detectors used in the test. The other equipment used in the test were DANTEC LVFA wind tunnel 435-1010 anemometer probes which measured air velocities at very low rates of speed. ANO sent these anemometers to multiple labs including Exelon Labs and National Aeronautics and Space Administration (NASA) for calibration. Unfortunately, none of the labs were able to successfully test the equipment to verify they were properly calibrated, and upon return to ANO, the anemometers were broken in transit. ANO was unable to verify the validity of the data collected during their thermal validation test.

Corrective Action Reference(s):

CR-A NO-C-2013-00374, CR-ANO-C-2013-0575, and

CR-ANO-C-2013-00576 Closure Basis

Since the ANO staff were unable to validate the data collected for the thermal validation test

, as required by CoC License Condition

9, the required test will still need to be

18 performed. However, the NRC has concluded that the wording from CoC License Condition

9 (Amendments

5-9) was not suitable to provide adequate test data to confirm the Holtec thermal analysis as described in the FSAR. The License Condition

9 required measuring air velocity within the annulus area between the canister and the overpack. The data provided in the ANO test was inconsistent and the test requirements listed in the CoC

Amendments

5 through 9 , License Condition 9

, needed to be revised to provide more consistent data that could be utilized by the vendor and the NRC to verify the analytical models from the FSAR. On May 31, 2016, NRC issued CoC

1014, License Amendment

10 , (ADAMS Accession

No. ML17237B994) which

modified the License Condition

9 thermal validation test to measure air velocity at the inlet vents and not the annulus area between the canister and the overpack.

The first general licensee to load a canister that exceeds 20

kW, under CoC

1014 License Amendment 10, is required to perform the thermal validation test using the new method as described in the

license condition. This test will provide sufficient data for the vendor to perform the required analysis and allow the NRC more stable results to review and conclude on the validation of the thermal model as described in the FSAR. A licensee in another region has described their intention of performing the required thermal validation test in the 2018 timeframe.

Unresolved Item

(Closed) Applicability of the ANO thermal validation test results to other HI-STORM 100 overpack configurations.

URI 07200013/2012001

-03 60855.1 Description

On February

3, 2012, Entergy submitted a letter to the NRC informing the agency of the completion of the thermal validation test (discussed above) and the completion of the Holtec analysis (ADAMS Accession No

. ML12038A177). On September

14, 2012, Holtec also informed the NRC of the completion of the ANO thermal validation test and provided a copy of Holtec Report

HI-2114925 (ADAMS Accession No

. ML12264A541) which evaluated the test data. The Holtec report indicated that the thermal model utilized in the licensing-based analysis methodology had predicted an air mass flow rate lower than the values measured in the ANO thermal test and, as such, demonstrated an overall conservatism of the licensing

-based methodology, thereby confirming the suitability of the methodology for demonstrating the thermal

-hydraulics safety of the HI

-STORM 100 cask system and satisfying the requirement of Condition

9. Holtec issued a statement to the other HI

-STORM 100 general licensee users concerning the ANO test on a HI

-STORM 100S, Version C , overpack and whether the results could be

applied to other cask models of the

100 series. Holtec Licensing Position Paper

HL-2011-01 was distributed to Holtec cask users dated August

5, 2011. Holtec concluded that the ANO test data demonstrated the validity of the thermal models

, and as such, the results of the ANO test could be applied to any of the HI

-STORM 100 overpack configurations. During a meeting on December

18, 2012 , between the NRC, ANO, and Holtec, the applicability of the ANO test to the other HI

-STORM overpacks was discussed extensively. A number of questions remained as to the sensitivity of the test results to the various configurations of the overpack dimensions and vent sizes. As such, the NRC needed to perform an independent evaluation to confirm Holtec's position. The independent review performed by the NRC was tracked as

an unresolved

item (URI 07200013/2012001

-03). Corrective Action Reference(s):

CR-ANO-C-2013-00374, CR-ANO-C-2013-0575, and CR

-ANO-C-2013-00576

19 Closure Basis

As described above in URI

07200013/2012001

-01, the NRC concluded that the wording from CoC License Condition

9 (Amendments

5-9) was not suitable to provide adequate test data to confirm Holtec's thermal methodology. On May 31, 2016, NRC issued CoC 1014 License Amendment

10 (ADAMS Accession No

. ML17237B994)

, which modified the License Condition

9 thermal validation test to measure air velocity at the inlets and not the annulus area between the canister and the overpack. The first general licensee to load a canister that exceeds 20

kW under CoC

1014 License Amendment

10, is required to perform the thermal validation test using the new method as described in the License Condition. Once the new data is collected and analyzed by the general licensee and the vendor, the information will be submitted to the NRC

for an independent review.

A general licensee in another region has described their intention of

performing the required thermal validation test in the 2018 timeframe.

20 EXIT MEETING S AND DEBRIEFS

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

On January 18, 2018, the inspector presented the results from the routine ISFSI inspection to M s. S. Pyle, Licensing Manager, and other members of the licensee staff.

On March 30, 2018, the inspector presented the radiation protection inspection results to

M r. R. Anderson, Site Vice President, and other members of the licensee staff.

On April 4, 2018, the inspector presented the quarterly resident inspector inspection results to Mr. J. Kirkpatrick, General Manager of Plant Operations, and other members of the licensee staff. On April 18, 2018, the inspectors presented the re

-exit of the quarterly resident inspector inspection results to Ms.

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

Attachment 1

DOCUMENTS REVIEWED

71111.01 - Adverse Weather Protection

Miscellaneous Documents

Number Title Revision M-2204 Piping & Instrument Diagram, Emergency Feedwater, Sheet 4 72 Procedures

Number Title Revision 2104.036 Emergency Diesel Generator Operations

94 2106.006 Emergency Feedwater System Operations

97 2106.032 Unit Two Freeze Protection Gui

de 27 1402.240 Inspection of Watertight Hatches

2 Condition Reports (CR

-ANO-) C-2018-00050 1-2017-03673 71111.04 - Equipment Alignment

Miscellaneous Documents

Number Title Revision CALC-91-E-0090-02 ANO-2 EDG Room Ventilation

2 CALC-91-R-2013-01 28 EC-24964 U-2 Emergency Diesel Generator Cycle

20 Heat Exchanger Thermal Performance Evaluation

EC-45962 2 K-4A/B 2013 Emergency Diesel Heat Exchanger Thermal Performance Test

EC-46332 U-2 Emergency Diesel Generator Thermal Performance Test Review 2011 EC-52442 2014 2 K-4A/B Thermal Performance Evaluation

EC-66265 U-2 SW Strainer D/P Spike Op Input

0 ER-ANO-2006-0248-000 GL-89-13 SW System Problems Affecting Safety

-Related Equipment

A1-2 Miscellaneous Documents

Number Title Revision M-2204 Piping & Instrument Diagram, Emergency Feedwater, S heet 4 72 M-2210 Piping & Instrument Diagram, Service Water, Sheet

1 - 4 83 STM-2-42 SW and ACW Systems

38 Procedures

Number Title Revision 1403.191 Motor Testing Using "MCE/EMAX"

11, 12 2104.029 Service Water System Operations

109 2104.036 Emergency Diesel Generator Operations

94 2104.044 Ventilation System Operations

44 2106.006 Emergency Feedwater System Operations

97 Condition Reports (CR

-ANO-) 1-2013-03239 1-2016-05663 1-2016-05675 1-2016-05676 1-2017-00186 1-2018-00132 2-2012-00762 2-201 5-02748 2-2015-02879 2-2015-05329 2-2016-00035 2-2016-00550 2-2016-02987 2-2016-03206 2-2016-03918 2-2016-04462 2-2017-05291 2-2017-05919 2-2018-00157 2-2018-00165 2-2018-00168 C-2013-03165 C-2016-05226 C-2016-05445 C-2017-04059 C-2017-04069 C-2017-04 775 C-2018-00277 C-2018-00441 Work Orders

52537116 52728726 497922-01 71111.05 - Fire Protection

Miscellaneous Documents

Number Title Revision/Date

Pre-Drill Brief

- ASOTH-FP-FBDRLS 9 EC-52999 Justification for Additional Non

-Q Battery Room Heating 00

A1-3 Miscellaneous Documents

Number Title Revision/Date

ER-ANO-2002-0145-00 Justification for Temporary Non

-Q Battery Room Heating

January 30, 2002 FBDRL-2018-03 Fire Drill

March 9, 2018 Procedures

Number Title Revision 2106.032 Unit Two Freeze Protection Guide

27 71111.06 - Flood Protection Measures Drawings Number Title Revision E-601 Electrical Plot Plan Outdoor Area, Sheet

1 1402.240 Inspection of Watertight Hatches

2 Work Orders

52747174 71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Procedures Number Title Revision OP-2202.001 Standard Post Trip Actions

16 OP-2202.002 Reactor Trip Recovery

11 OP-2203.009 Fire Protection System Annunciator Corrective Actions

32 OP-2203.025 RCP Emergencies

18 OP-2203.034 Fire or Explosion

21 71111.12 - Maintenance Effectiveness

Drawings Number Title 234C7880F Induction Motor

A1-4 Miscellaneous Documents

Number Title Revision 117 Engineering Evaluation, SW Pumps

6 2015 U-2 SW System Health Report Q

1 , Q 2 , Q 3 , Q 4 2016 U-2 SW System Health Report

Q 1 , Q 2 , Q 4 2017 U-2 SW System Health Report Q

2 EC-28463 SW System 0 N 1000.006-P E-Doc, SW System Ops

53 TDG 080 1710 Triclad Vertical Induction Motors

3 Procedures

Number Title Revision 1304.125 Unit 1 RPS

-A/CRD Breaker Trip Test

26 1309.013 Flow Rate Data

2104.029 SW System Ops

109 2203.022 Loss of SW Tech Guidelines

14 2311.002 Flow Rate Data

2411.102 U-2 Slide Gate and SW Bay Cleaning/Inspection

EN-DC-204 Maintenance Rule Scope and Basis

4 EN-DC-205 Maintenance Rule Monitoring

6 EN-FAP-OM-012 Prompt Investigation and Notifications, Attn.

7.4 9 EN-LI-118 ANO Response to Cold Weather Shad Runs 25 1402.240 Inspection of Watertight Hatches

2 Condition Reports (CR

-ANO-) 1-2017-00965 2-2014-02814 2-2015-00083 2-2015-00129 2-2015-002 68 2-2016-01808 2-2016-02351 2-2016-02611 2-2017-01162 2-2017-05280 2-2017-05281 2-2017-05329 2-2017-05759 2-2018-00044 2-2018-00045 2-2018-00157 2-2018-00300 2-2018-00445 2-2018-00797 C-2017-00287 C-2018-00299 C-2018-01623 1-2017-03673

A1-5 Work Orders

189034 435369 453805 468095 486027 489032 51803722 52652306 52711156 52713201 52715932 52728009 52766896 52784316 71111.13 - Maintenance Risk Assessments and Emergent Work Control

Miscellaneous Documents

Number Title Revision COPD-024 Risk Assessment Actions

64 Procedures

Number Title Revision 1107.001 Electrical System Operations

115 2104.029 Service Water System Operations

109 2203.003 CEA Malfunction

24 EN-FAP-OM-021 Critical Decision Procedure

5 EN-OP-119 Protected Equipment Postings

9 EN-WM-104 On Line Risk Assessment

16 Condition Reports (CR

-ANO-) C-2018-00474 C-2018-00475 Work Orders

490410 71111.15 - Operability Determinations and Functionality Assessments

Drawings Number Title A2001S01 ANO 500/161KV SW STA Station O

ne-Line In-Service Diagram E-2100 Schematic Diagram Diesel Generator 2K4A ACB 152

-308 E-2276 Schematic Diagram Service Water Pump 2P4B

E-2361 Schematic Diagram Containment Cooling 2VSF1A

E-2361 Schematic Diagram Containment Cooling 2VSF1B

A1-6 Miscellaneous Documents

Number Title Date 00-R-2011-01 Calculation

OPS-152A SU1 Outage Checklist

- Unit 1 - 72-Hour TC August 29, 2013 OPS-152B SU3 Outage Checklist

- Unit 2 - 72-Hour TC August 29, 2013 Procedures

Number Title Revision 1106.006 Emergency Feedwater Pump Operation

100, 101, 102

Condition Reports (CR

-ANO-) 1-2000-00068 1-2017-01820 1-2018-00086 2-2000-00074 2-2018-00055 2-2018-00065 2-2018-00088 C-2018-00389 C-2018-00474 C-2018-00475 Work Orders

490410-16 71111.18 - Plant Modifications

Miscellaneous Documents

Number Title Revision/Date

CALC-86E-0020-01 1E Station Battery 2D11 Duty Cycle and Sizing Calculation

18 EC-52999 Justification for Additional Non

-Q Battery Room Heating

00 ER-ANO-2002-0145-00 Justification for Temporary Non-Q Battery Room Heating

January 30, 2002 STM 2-32-5 125 VDC Electrical Distribution

25 Procedures

Number Title Revision 2106.032 Unit Two Freeze Protection Guide

27

A1-7 Condition Reports (CR

-ANO-) 2-2003-00041 2-2014-00345 Work Orders

4906 46 71111.19 - Post-Maintenance Testing

Procedures

Number Title Revision 2304.237 Post Maintenance Verification

16 Condition Reports (CR

-ANO-) 1-2018-01107 2-2018-00356 Work Orders

494916 71111.22 - Surveillance Testing

Miscellaneous Documents Number Title Revision/Date CALC-95-R-0014-02-01 MWO50235000

MWO 50235239 MWO 50235641 OPS-152A SU1 Outage Checklist

- Unit 1 - 72-Hour TC August 29, 2013 OPS-152B SU3 Outage Checklist

- Unit 2 - 72-Hour TC August 29, 2013 SEP-ANO-1-I ST-1 ANO-1 Inservice Testing Basis Document

3 Procedures

Number Title Revision 1104.209 SW Pump Performance Curves

A1-8 Procedures

Number Title Revision 1106.006 Emergency Feedwater Pump Operation

100, 101, 102

1107.001A Unit 1 XFMR Outage Checklist

115 1304.125 Unit 1 RPS

-A/CRD Breaker Trip Test

26 2104.029 SW Pump Performance Curves

Condition Reports (CR

-ANO-) 1-2009-01820 1-2017-00965 1-2018-00086 1-2018-00631 2-2017-05885 C-2018-00474 Work Orders

52747144 71124.01 - Radiological Hazard Assessment and Exposure Contro

ls Air Sample Surveys

Number Title Date AS-ANO-2018-04648 RAB 10 - P 36 A Makeup Pump Tear Down

March 2 , 2018 AS-ANO-2018-04660 RAB 11 - AMS-4 Alarm March 7 , 2018 AS-ANO-2018-04665 RAB 121 - Replace 2RE - 8221-2 Blower Pump UNPR

March 9 , 2018 Audits and Self-Assessments

Number Title Date LO-ALO-2017-00025 Self-Assessment: Radiation Safety

- Hazard Assessment and Airborne Controls

March 22 , 2017 QA-14/15-2017-ANO-01 Combined Radiation Protection and Radwaste

November 6 , 2017 Miscellaneous Document

s Number Title Date NSTS Annual Inventory Reconciliation Report

January 11 , 2018 ANO Alpha Hazard Evaluation

May 3 , 2017

A1-9 Miscellaneous Document

s Number Title Date ANO-2017-0067 Spent Fuel Pool Inventory

- Non-Fuel Items

August 22 , 2017 ANO-2017-0093 2017 Radiation Energy Distribution Evaluation December 7 , 2017 52742701 Annual Inventory of Non

-Installed Radioactive Sources

February 20 , 2018 52745968 Semi Annual Leak Test of Sealed Sources

February 15 , 2018 Procedures

Number Title Revision EN-RP-100 Radiation Worker Expectations

12 EN-RP-101 Access Control for Radiologically Controlled Areas

14 EN-RP-102 Radiological Control

5 EN-RP-104 Personnel Contamination Events

10 EN-RP-105 Radiological Work Permits

18 EN-RP-106 Radiological Survey Documentation

7 EN-RP-108 Radiation Protection Posting

20 EN-RP-109 Hot Spot Program

5 EN-RP-121 Radioactive Material Control

14 EN-RP-123 Radiological Controls for Highly Radioactive Objects

1 EN-RP-143 Source Control

13 EN-RP-152 Conduct of Radiation Protection

3 Radiation Surveys

Number Title Date 1609-0457 U 1 AUX 335' EL - F 3A/F 3B Filter Rooms

September

19 , 2016 1703-0336 U 1 AUX Bldg - T-15 Tank Room March 14 , 2017 1801-0490 U 1 AUX 335' EL F 2 Seal Injection Filter Room

January 31 , 2018 1802-0204 Semi Annual Source Leak Test

February 1

4 , 2018

A1-10 Radiation Work Permits

Number Title Revision 20181401 Radiation Protection Activities During

1 R 27 00 20181407 Decontamination Activities During !R

27 (Bulk Work)

00 20181412 1 R 27 Locked High Radiation Area Activities (Bulk Work)

01 20181425 RCP Motor Maintenance During

1 R 27 00 20181430 Reactor Disassembly/Re

-Assembly, and Support Activities

00 20181432 De-Fuel & Re-Fuel the Reactor

00 20182053 Spent Fuel Activities

- Unit 2 00 Condition Reports (CR

-ANO-) 1-2018-00585 1-2018-00997 1-2018-01273 2-2017-01634 2-2017-04273 2-2017-04634 2-2017-05337 2-2017-06115 C-2017-00890 C-2017-00946 C-2017-01105 C-2017-03822 C-2017-03929 C-2018-01264 Fleet Condition Reports (CR

-HQN-) 2017-00179 2017-00848 2017-00974 71124.02 - Occupational ALARA

Planning and Controls

ALARA Planning, In

-Progress Reviews, and Post

-Job Reviews

Number Title Date 20171070 Core Bore NFPA 805 Project and Support Activities

March 6, 2018 20181070 Core Bore NFPA 805 Project and Support Activities

March 5, 2018 2018143 0 Reactor Disassembly, Reassembly, and Support Activities

June 17, 2017 Audits and Self

-Assessments

Number Title Date LO-ALO-2017-00023 Self-Assessment: Radiation Safety

- ALARA & Dose Assessment

September 11, 2017 QA-14/15-2017-ANO-01 Quality Assurance Audit: Combined Radiation Protection and Radwaste

November 6, 2017

A1-11 Miscellaneous Documents

Number Title Date Letdown Heat Exchanger (E

-29A/B) Flush Plan

March 28, 2018 TSR 18-1-063 Letdown Heat Exchangers, E

-29A and E-29 B December 7 , 2017 TSR 18-1-064 RBD-11A & RBD-12A / Makeup System

December 7, 2017 TSR 18-1-123 Letdown Cooler E

-29A&B Inlet/Outlet Isolation

December 7, 2017 Procedures

Number Title Revision EN-RP-105 Radiological Work Permits

18 EN-RP-110 ALARA Program

14 EN-RP-110-03 Collective Radiation Exposure Guidelines

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

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

1 Radiation Work Permits

Number Title Revision 20171070 Core Bore NFPA 805 Project and Support Activities 03 20181070 Core Bore NFPA 805 Project and Support Activities

03 20181401 Radiation Protection Activities During 1R27

00 20181414 ALARA Activities During 1R27

00 20181420 Scaffold Installation / Removal Non

-LHRAs - 1R27 00 20181430 Reactor Disassembly, Reassembly, and Support Activities

00 20181900 Emergent Maintenance Activities During 1R27

00 Condition Reports (CR

-ANO-) 1-2018-00336 1-2018-00508 1-2018-00849 2-2017-05526 C-2017-04230 C-2017-04551 C-2017-04692 C-2018-00851

A1-12 Fleet Condition Reports (CR

-HQN-) 2017-01791 71151 - Performance Indicator Verification

Procedures

Number Title Revision EN-LI-114 Regulatory Performance Indicator Process

7, 8 71152 - Problem Identification and Resolution

Miscellaneous Documents

Number Title Revision EC-66265 U-2 SW Strainer D/P Spike Op Input

0 ER-ANO-2006-0248-000 GL-89-13 SW System Problems Affecting Safety

-Related Equipment

Condition Reports (CR

-ANO-) 1-2013-03239 1-2016-05663 1-2016-05675 1-2016-05676 1-2017-00186 1-2018-00132 2-2012-00762 2-2015-02748 2-2015-02879 2-2015-05329 2-2016-00035 2-2016-00550 2-2016-02987 2-2016-03206 2-2016-03918 2-2016-04462 2-2017-05291 2-2017-05919 2-2018-00157 2-2018-00165 2-2018-00168 C-2013-03165 C-2016-05226 C-2016-05445 C-2017-04059 C-2017-04069 C-2017-04775 C-2018-00277 C-2018-00441 C-2018-0299 71153 - Follow-up of Events and Notices of Enforcement Discretion

Miscellaneous Documents

Number Title CALC-16-E-0017-01 Tornado Missile Shield for Door 77, Room 144

EC 67019 Door 77, room

144 Tornado Generated Missile Barrier

ECN 73255 Resolution of Rebar Interferences for DR

-77 Missile Barrier

A1-13 Miscellaneous Documents

Number Title LER 05000313/2016

-002-00 Tornado Missile Vulnerability Resulting in Condition Prohibited By Technical Specifications

Condition Reports (CR

-A NO-) 1-2016-01788 Other Activities

Design Basis Documents

Number Title Revision/Date 72.212 72.212 Report for ANO ISFSI

10 Area-TLD Report

Review of 2014 Area Monitoring Results (1

st/2 nd half) February 2015 Area-TLD Report

Review of 2015 Area Monitoring Results (1

st/2 nd half) February 2016 Area-TLD Report

Review of 2016 Area Monitoring Results (1

st/2 nd half) February 2017 CoC 1014 CoC and Technical Specifications for HI

-STORM 100

Amendment 5

ISFSI FSAR

HI-STORM 100 ISFSI Final Safety Analysis Report 7 LTR-PAR-17-081 Evaluation of XSAM Periodic Test ANO, Two Block

November 20 , 2017 WTHQN-2015-277 Surveillance Activity Report

April 15, 2015 WTHQN-2015-605 Surveillance Activity Report

April 15 , 2015 WTHQN-2016-774 Surveillance Activity Report December 9 , 2016 Miscellaneous Documents

Number Title Date ANO-1708-0273 Survey of Dry Fuel Pad

August 16, 2017 ANO-1708-0279 Survey of CTF Dry Fuel Storage Pad

August 16 , 2017

A1-14 Miscellaneous Documents

Number Title Date WTHQN-2016-775 Surveillance Activity Report

December 9 , 2016 WTHQ N-2016-776 Surveillance Activity Report

February 16, 2016 WTHQN-2016-777 Surveillance Activity Report

December 15 , 2016 WTHQN-2017-111 Surveillance Activity Report

January 25 , 2017 WTHQN-2017-372 Surveillance Activity Report

April 27, 2017 WTHQN-20 17-453 Surveillance Activity Report

June 9 , 2017 Procedures

Number Title Revision 1015.003B Unit Two Operations Logs

80 EDR-1 Generic Licensing Topical Report for L

-3 Crane 3 EN-DC-215 Fuel Selection for Holtec Dry Cask Storage for Canisters 48 through 57 6 EN-LI-100 Process Applicability Determination

20 EN-LI-101 10 CFR 50.59 Evaluations

15 EN-LI-112 10 CFR 72.48 Evaluations

12 EN-LI-115 HI-STORM 100 ISFSI Licensing Document Preparation and Control 7 EN-RP-210 Area Monitoring Program

1 OP-3403.004 HI-STORM 100 System Equipment Preparation

18 OP-3403.005 HI-STORM 100 System Loading Operations

40 OP-3403.008 HI-TRAC and MPC Preparations for Fuel Loading

1 OP-3403.009 MPC Receipt Inspections

1 OP-3403.010 HI-STORM Overpack Receipt Inspection

s 1 OP-3406.005 Hi-STORM and HI

-TRAC Transport Operations

14 OP-3406.006 Forced Helium Dehydration System Operations

9 OP-3406.007 Supplemental Cooling System Operations

8

A1-15 72.48 Evaluations

Number Title Date DFS-15-001 72.48 Evaluation, Foreign Material December 22 , 2015 DFS-16-001 72.48 Evaluation, Application of Concrete Sealant

January 21 , 2016 Condition Reports (CR

-ANO-) 1-2017-3441 1-2017-3445 1-2017-3447 1-2017-3448 1.2017-3449 1.2017-3450 1-2017-3451 1-2017-3538 1-2017-3540 1-2017-3541 1-2017-3555 1-2016-0403 2-2015-2420 2-2016-0359 2-2016-2071 C-2015-0849 C-2015-0918 C-2015-0969 C-2015-1185 C-2015-2297 C-2015-2765 C-2015-3387 C-2015-4664 C-2015-4693 C-2015-4905 C-2015-4971 C-2016-0038 C-2016-0834 C-2016-0848 C-2016-1344 C-2016-2844 C-2016-3647 C-2016-4458 C-2017-2506 C-2017-2850 Engineering Changes

EC-15295 EC-37094 EC-42379 EC-45077 EC-48646 EC-48806 EC-52044 EC-52619 EC-54103 EC-59072 EC-63881 EC-73641 Work Orders

00065585 00408695 00419603 00439666 00479654 00488244 00489244 52393253 52576506 52629825 52629826 52638961 52663017 52667631 52687172 52687173 52701892 52707684 52719037

Attachment 2

The following items are requested for the

Occupational Radiation Safety Inspection

Arkansas Nuclear One

March 26 thru 30, 2018

Integrated Report 2018001

Inspection areas are listed in the attachments below.

Please provide the requested information on or before March 9, 2018

. Please submit this information using the same lettering system as below. For example, all contacts and phone numbers for Inspection Procedure 71124.0

1 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 on

-site 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 contact Natasha Greene at (817) 200

-1154 or natasha.greene@nrc.gov. 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.

A2-2 1. Radiological Hazard Assessment and Exposure Controls (71124.01) and Performance Indicator Verification (71151) Date of Last Inspection:

April 10, 2017

A. List of contacts and telephone numbers for the Radiation Protection Organization Staff and Technicians

B. Applicable organization charts

C. Audits, self

-assessments, and LERs written since date of last inspection

, related to this inspection area

D. Procedure indexes for the radiation protection procedures

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.

1. Radiation Protection Program Description

2. Radiation Protection Conduct of Operations

3. Personnel Dosimetry Program

4. Posting of Radiological Areas

5. High Radiation Area Controls

6. RCA Access Controls and Radiation Worker Instructions

7. Conduct of Radiological Surveys

8. Radioactive Source Inventory and Control

9. Declared Pregnant Worker Program

F. List of corrective action documents (including corporate and sub

-tiered systems) since date of last inspection

a. Initiated by the radiation protection organization

b. Assigned to the radiation protection organization

NOTE: The lists should indicate the significance level

of each issue and the search criteria used. Please provide in document formats which are "searchable" so that the inspector can perform word searches.

If not covered above, a summary of corrective action documents since date of last inspection

involving unmonitored releases, unplanned releases, or releases in which any dose limit or administrative dose limit was exceeded (for Public Radiation Safety Performance Indicator verification in accordance with IP 71151)

G. List of radiologically significant work activities scheduled to be conducted during the inspection period (If the inspection is scheduled during an outage, please also include a list of work activities greater than 1 rem, scheduled during the outage with the dose estimate for the work activity.)

H. List of active radiation work permits

A2-3 I. Radioactive source inventory list

a. All radioactive sources that are required to be leak tested

b. All radioactive sources that meet the 10 CFR Part 20, Appendix E, Category 2 and above threshold. Please indicate the

radioisotope, initial and current activity (w/assay date), and storage location for each applicable source.

J. The last two leak test results for the radioactive sources inventoried and required to be leak tested.

If applicable, specifically provide a list of all radioactive source(s) that have failed its leak test within the last two years

K. A current listing of any non

-fuel items stored within your pools, and if available, their appropriate dose rates (Contact / @ 30cm)

L. Computer printout of radiological controlled area entries greater than 100 millirem since the previous inspection to the current inspection entrance date. The printout should include the date of entry, some form of worker identification, the radiation work permit used by the worker, dose accrued by the worker, and the electronic dosimeter dose alarm set-point used during the entry (for Occupational Radiation Safety Performance Indicator verification in accordance with IP 71151).

A2-4 2. Occupational ALARA Planning and Controls (71124.02) Date of Last Inspection:

November 6, 2017

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.

1. ALARA Program

2. ALARA Committee 3. Radiation Work Permit Preparation

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

-tiered systems) written since date of last inspection, 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 in document formats which are "searchable" so that the inspector can perform word searches.

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 o

f record) I. Outline of source term reduction strategy

J. If available, provide a copy of the ALARA outage report for the most recently completed outages for each unit

K. Please provide your most recent Annual ALARA Report.