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Discusses Insp Repts 50-313/96-27 & 50-368/96-24 on 961211 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000
	ML20137Q645
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/09/1997
From:	Merschoff E; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Hutchinson C; ENTERGY OPERATIONS, INC.
Shared Package
ML20137Q648	List: ML20137Q645; ML20137Q669;
References
	EA-96-512, NUDOCS 9704110063
	Download: ML20137Q645 (6)
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April 9, 1997

EA 96 512

C. Randy Hutchinson, Vice President

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Operations !

Arkansas Nuclear One

Entergy Operations, Inc.

1448 S.R 333

Russellville, Arkansas 72801-0967

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF civil PENALTY -

! $50,000 (NRC Inspection Report 50-313:368/96-27)

Dear Mr. Hutchinson:

This refers to the predecisional enforcement conference conducted in Arlington, Texas, on

March 28,1997 with Entergy Operations, Inc. (Entergy) representatives. The conference

was conducted to discuss apparent violations of NRC requirements associated with an

October 17,1996 fire at / rkansas Nuclear One (ANO), Unit 1, as documented in NRC -

Inspection Report 50-313:368/96-27, issued February 3,1997. The inspection was

conducted October 22-29 and November 21-25,1996, and was finalized in a telephonic

exit meeting on December 11,1996.

The apparent violations described in the inspection report involved severalinadequacies in

NRC-required reactor coolant pump oil collection systems at ANO, and three examples of

'

inadequate responses to plant conditions which indicated the potential for a fire (i.e.,

inadequate corrective action, as required by 10 CFR Part 50, Appendix B, Criterion XVI).

At the conference, Entergy expressed disagreement with parts of the apparent fire

protection violations, contending that the oil collection system for the reactor coolant

pumps was not required to collect oil spray from lift oil piping leaks, nor to collect leakage

from " remote" oil filllines. Entergy did not explicitly disagree with the corrective action

violations. However, Entergy's position was that plant personnel had responded

reasonably to oilleaks and smoke in light of their lack of understanding of the " wicking" I

phenomenon which created the potential for oil-soaked insulation to ignite at a lower than

expected temperature.

The NRC considered Entergy's fire protection arguments but has concluded that 10 CFR j

Part 50, Appendix R,is clear with regard to these reactor coolant pump components being

protected by oil collection systems. Based on our discussions during the conference, we f

have clarified the violation to include the failure to protect the fill connection on the Unit 1

8 reactor coolant pump and to clarify that the flanged connections were not protected on

the lower reservoir transmitters. We also deleted one of the apparent examples of an

Appendix B, Criterion XVI violation. Specifically, we deleted the examole involving oil

found on the floor of the Unit 1 containment building by radiation protection personnel

during the outage because, as discussed during the conference, the small amounts of oil

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involved did not represent a clear opportunity to determine the source of the leak and take

- corrective action.

Therefore, based on the information developed during the inspection and the information

that was provided during the conference, the NRC has determined that violations of NRC

requirements occurred. These violations are cited in the enclosed Notice of Violation and .

Proposed imposition of Civil Penalty; the circumstances surrounding the violations were

described in detail in the subject inspection report.

The violations include: 1) a failure to maintain an adequate lube oil collection system for

reactor coolant pumps, which created the potential for a fire when oil spray from a cracked

weld accumulated in fibrous insulation; and 2) a failure in two instances to take prompt

action to identify and correct conditions which resulted in a fire in the ANO Unit 1

containment building on October 17,1996. These violations appt.ar to have resulted from

a lack of sensitivity to fire protection requirements related to reactor coolant pump lube oil

collection systems and to plant conditions which indicateri a potential for a containment

fire to occur.

The October 17,1996 fire was quickly extinguished and did not affect the safety of the

plant. Nonetheless, the NRC finds the fire protection inadequacies, coupled with the plant -

staff's inadequate response to indications of a fire, i.e., oil soaked insulation which was

reported to be smoking excessively during plant heat-up, unacceptable performance.

Therefore, these violations have been classified in the aggregate as a Severity Levelill

problem, in accordance with the " General Statement of Pc"cy and Procedure for NRC

Enforcement Actions" (Enforcement Policy), NUREG-1600.

The NRC acknowledges that Entergy has taken or planned a number of corrective actions

in response to these violations, all of which were discussed at the conference. In brief,

these actions involve: 1) training and procedural revisions to heighten sensitivity to smoke,

oil leaks, lube oil collection system requirements and the potential for reduced auto-ignition

- temperatures of oil-soaked insulation; and 2) plant modifications and administrative

measures to address the various inadequacies in reactor coolant pump lube oil collection

systems.

In accordance with the Enforcement Policy, a civil penalty with a base value of $50,000 is

considered for a Severity Levellli problem. Because your facility has been the subject of

escalated enforcement actions within the last 2 years,' the NRC considered whether

Entergy should be given credit for identi// cation and Corrective Action in accordance with

the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. The

violations were discovered only because the fire occurred. In that plant staff missed

opportunities to take action to prevent the fire, the NRC has determined that Entergy

should not be given credit for identification. The NRC has determined that Entergy should

' A $50,000 civil penalty was issued September 6,1996, for violations related to

improper maintenance on main steam safety valves. >

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Entergy Operations, Inc. -3-

be given credit for its corrective actions, summarized above, which were prompt and-

comprehensive. Consideration of these factors results in the assessment of a base civil-

penalty.

!

Therefore, to emphasize the importance of adherence to fire protection requirements in the

design and operation of the f acility, and the importance of reacting to plant conditions

i indicating a potential for a fire, I have been authorized, after consultation with the Director,

Office of Enforcement, to issue the enclosed Notice of Violation and Proposed imposition

of Civil Penalty (Notice) in the amount of $50,000.

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

enclosed Notice when preparing your response. In your response, you should document

the specific ' actions taken and any additional actions you plan to prevent recurrence. The

NRC will use your response, in part, to determine whether further enforcement action is

necessary to ensure compliance with regulatory requirements.

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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, !

its enclosure, and your response will be placed in the NRC Public Document Room (PDR).

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Sincerely,, ;

,

Ellis W. Merschof

Regional Admi ator ,

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Docket Nos. 50-313;50 368

License Nos. DPR-51; NPF-G

Enclosure: Notice of Violation and

Proposed imposition of Civil Penalty !

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. cc w/ Enclosure: i

Executive Vice President

& Chief.Operatir.g Officer

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Entergy Operations, Inc.

P.O. Box 31995 !

Jackson, Mississippi 39286-1995 ,

Vice President

Operations Support l

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Entergy Operations, Inc.

P.O. Box 31995

Jackson, Mississippi 39286 ;

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Entergy Operations, Inc. -4-

' Manager, Washington Nuclear Operations

ABB Combustion Engineering Nuclear

Power

12300 Twinbrook Parkway, Suite 330.

Rockville, Maryland 20852

County Judge of Pope County

Pope County Courthouse

Russellville, Arkansas 72801 ,

Winston & Strawn

'

1400 L Street, N.W.

. Washington, D.C. 20005 3502

Bernard Bevill, Acting Director

Division of Radiation Control and

Emergency Management

Arkansas Department of Health

4815 West Markham Street, Slot 30

Little Rock, Arkansas 72205 3667

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Manager

Rockville Nuclear Licensing

Framatome Technologies 1

1700 Rockville Pike, Suite 525

Rockville, Maryland 20852

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Entergy Operations, Inc. -5-

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IBarnes (IXB) KBrockman (KEB)

CVanDenburgh (CAV) KKennedy (KMK)

DOCUMENT NAME: G:\EA\ DRAFT \EA96512.DFT

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RA Reading File GSanborn-EAFile

RIV Files MIS Coordinator

- PAO Chief, DRS/EB

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RSLO Chief, DRP/C

LWilliamson, Ol

RIV Files

E-Mall DISTRIBUTION:

OEMAll JDyer (JED2)

T PGwynn (TPG) WBrown (WLB)

GSanborn (GFS) GMVasquez (GMV)

BHenderson (BWH) MHammond (MFH2) i

CHackney (CAH) DKunihiro (DMK1)

Art Howell (ATH) DChamberlain (DDC) ;

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KPerkins (KEP) LYandell (LAY

IBarnes (IXB) KBrockman (KEB)

CVanDenburgh (CAV) KKennedy (KMK) .

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DOCUMENT NAME: G:\EA\ DRAFT \EA96512.DFT

To receive copy of document. Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy

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ML20137Q645

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